Corporate Expatriation, Inversions, and Mergers: Tax Issues
This report discusses relevant portions of the U.S. corporate income tax system and how inversions have commonly been structured. It also looks at how Congress and Department of the Treasury have reduced the benefits of inversions, including The American Jobs Creation Act, as well as post-2004 inversions and treasury regulations, and policy options.
International Corporate Tax Rate Comparisons and Policy Implications
This report focuses on the global issues relating to tax rate differentials between the United States and other countries. It provides tax rate comparisons; discusses policy implications, including the effect of a corporate rate cut on revenue, output, and national welfare; and discusses the outlook for and consequences of a revenue neutral corporate tax reform.
FORMULA APPORTIONMENT: IS IT BETTER THAN THE CURRENT SYSTEM AND ARE THERE BETTER ALTERNATIVES?
This analysis of formula apportionment compared to the current U.S. system recognizes that income shifting has two main sources, excess returns attributable to intangibles and debt, and that a major goal of income division systems is preserving neutrality between arm s length and related party transactions. A model demonstrates that separate accounts (SA) and formula apportionment (FA) distort behavior along different margins. Simulations indicate that FA has no clear advantage over SA. Static estimates of U.S. tax revenues under FA suggest potentially large increases, but simulations show that revenue under FA and SA is similar once behavioral responses are taken into account.