期刊名称：Departmental Discussion Papers / University of Glasgow, Department of Economics
出版年度：2009
卷号：1
出版社：University of Glasgow, Department of Economics
摘要：Using data from the International Revenue Service, this paper explores the e.ects of
corporate taxation on U.S. capital invested abroad and on tax planning practices (divi-
dend payments, income shifting, and passive investment). The econometric analysis ¡¥rst
indicates that investment is strongly in¡ãuenced by average tax rates, with a magni¡¥ed im-
pact for particularly low-tax rates implying that the attractiveness of low-tax countries is
not weakened by anti-deferral rules and cross-crediting limitations. Further explorations
suggest that ¡¥rms report higher pro¡¥t and are less likely to repatriate dividends when
they are located in low-tax jurisdictions. Firms also report higher Subpart F income in
countries in which they shift their pro¡¥t, suggesting that cross-crediting provides an in-
centive to shift passive income in low-tax countries and that passive investment can be an
alternative strategy to minimize taxes when active investment opportunities are lacking.
Finally, the paper estimates the role of e.ective transfer pricing regulation on income
shifting activities using the quality of host countries' law enforcement. It appears that
low degrees of law enforcement are associated with higher income-shifting.
关键词：International taxation, U.S. capital, income shifting, dividend payments,
Subpart F income, tax credit system.
