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Corporate Inversion

United States. Congress. Senate. Committee on Appropriations. Subcommittee on Treasury and General Government

Published: 2003

Total Pages: 72


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The book deals with tax planning with holding companies located in Europe, Asia of the Caribbean. It analyses the problem of repatriating U.S. profits from Europe, going far beyond the routing of income via different companies. Instead, the approach includes an analysis of the interdependencies between international tax competition, holding company regimes, and tax planning concepts in order to establish a basis for tax planning measures regardless of the fast changing legal environment for holding companies in the different countries.
There is no consensus on how strongly the Tax Cuts and Jobs Act (TCJA) has stimulated U.S. private fixed investment. Some argue that the business tax provisions spurred investment by cutting the cost of capital. Others see the TCJA primarily as a windfall for shareholders. We find that U.S. business investment since 2017 has grown strongly compared to pre-TCJA forecasts and that the overriding factor driving it has been the strength of expected aggregate demand. Investment has, so far, fallen short of predictions based on the postwar relation with tax cuts. Model simulations and firm-level data suggest that much of this weaker response reflects a lower sensitivity of investment to tax policy changes in the current environment of greater corporate market power. Economic policy uncertainty in 2018 played a relatively small role in dampening investment growth.
This paper reviews the rapidly growing empirical literature on international tax avoidance by multinational corporations. It surveys evidence on main channels of corporate tax avoidance including transfer mispricing, international debt shifting, treaty shopping, tax deferral and corporate inversions. Moreover, it performs a meta analysis of the extensive literature that estimates the overall size of profit shifting. We find that the literature suggests that, on average, a 1 percentage-point lower corporate tax rate will expand before-tax income by 1 percent—an effect that is larger than reported as the consensus estimate in previous surveys and tends to be increasing over time. The literature on tax avoidance still has several unresolved puzzles and blind spots that require further research.
In May 2019, the Inclusive Framework adopted a Programme of Work, which was endorsed by the G20 Finance Ministers and G20 Leaders in June 2019. The Programme of Work outlined proposals in two pillars that could form the basis for a multilateral consensus-based solution. This report presents an ex ante analysis of the economic and tax revenue implications of the Pillar One and Pillar Two proposals under discussion by the Inclusive Framework as part of its work to address the tax challenges arising from the digitalisation of the economy.
Global investment patterns mean that effective taxation of foreign investors is of increasing importance to the economies of lower income countries. It is thus of considerable concern that the historical framework for cross-border income tax arrangements is not always well suited to allow low-income countries (LICs) effectively to generate tax revenues from profits on foreign direct investment (FDI). Several aspects of this framework contribute to the problem. This paper discusses, in particular, the likely effect of a shift by major economies from the system of worldwide corporate taxation toward a territorial system on the volume, distribution, and financing of FDI, focusing on LICs. It then empirically analyzes bilateral outbound FDI data for the UK for 2002–10 to determine whether the move to territoriality made corporations more sensitive to hostcountry statutory tax rates. Supporting evidence for this hypothesis is found for FDI financed from new equity.
How America was Tricked on Tax Policy explains how regular citizens were “tricked” by the outdated view of economists that much heavier taxation of labor rather than capital is economically justifiable. The truth is that workers pay their taxes while the rich pay very little. Based on reputable sources of information, including publications of the Organization for Economic Cooperation and Development (OECD), official statistics data, and the publications in high-ranked journals, the book paves the way for a new policy-making process aimed to achieve more sustainable taxation and to increase the wellbeing of citizens as the main goal of any modern state policy. Dealing with critically important and underexplored topics in tax policy, the book challenges an enshrined dogma that is rarely challenged at the level of policy. In doing so, this book envisions policy changes that could be highly impactful in a new political administration. This book proposes that governments should look for not just corporate income tax rate reduction when announcing their tax reforms but should equally focus on the reduction of the overall tax burden on labor. The negative impact and high social cost of wage taxation is exemplified by the key areas of tax policy that are relevant for every wealthy state, such as taking due care of public health, investing in education and wellbeing of children, and supporting small business for the overall benefit to society. The book compellingly argues how tax policy could be improved by incorporating science and scientific methods.
Migration has become an increasingly important phenomenon for societies, especially given its highly controversial political dimension. The complexity of the migrant integration process and its many varieties present challenges to policymakers who need high-quality information on which to base decisions. Nowhere is this necessity more pressing than in the development of relevant tax rules that meet the basic requirements of efficiency and equity. Moreover, the ascent of the so-called emerging economies coupled with the stagnation of the richest economies of the world implies reform of the current competition-based international tax regime and the adoption of a more cooperative paradigm. This important and timely book, for the first time in such depth, explores such aspects of the problem as the following: - migration for tax reasons, especially corporate "inversions" (change in corporate residence for tax purposes); - tax consequences related to individuals who receive free or subsidized education in one country and profit from it in another; - taxing cross-border retirement income; and - migration-related aspects of tax preferential treatment of the elderly. With particular emphasis on the effects and opportunities created by the changing international tax regime - and with attention to the role of tax treaties and recent court cases - chapters by well known tax experts present evidence on the consequences of migration in all its facets and simulate the effects of several recently enacted and proposed changes in tax law in European countries, the United States, and other jurisdictions. The grounded propositions and recommendations offered in this deeply informed book will allow policymakers to draft tax-residence rules that minimize distortion and promote fairness. The book will also be of interest to tax law practitioners and other tax specialists, migration experts, and academics investigating one of the crucial political issues of our time.