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International Taxation and Multinational Activity$
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James R. Hines

Print publication date: 2001

Print ISBN-13: 9780226341736

Published to Chicago Scholarship Online: February 2013

DOI: 10.7208/chicago/9780226341750.001.0001

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PRINTED FROM CHICAGO SCHOLARSHIP ONLINE (www.chicago.universitypressscholarship.com). (c) Copyright University of Chicago Press, 2021. All Rights Reserved. An individual user may print out a PDF of a single chapter of a monograph in CHSO for personal use.date: 26 September 2021

Tax Planning by Companies and Tax Competition by Governments

Tax Planning by Companies and Tax Competition by Governments

Is There Evidence of Changes in Behavior?

(p.113) 5 Tax Planning by Companies and Tax Competition by Governments
International Taxation and Multinational Activity

Harry Grubert

University of Chicago Press

Many claims have been made in recent years, both by the popular media and by prominent economists, that we are living in a period of more aggressive tax planning by multinational corporations (MNCs) and more intense tax competition by governments. This chapter examines and analyzes changes in average effective tax rates in sixty countries to determine the responses of governments to the new global environment. It looks at various areas of MNC and government behavior, including the effective tax rates that MNCs pay to host governments. After reviewing the incentives for tax planning by MNCs from the United States and how these may have changed as a result of the Tax Reform Act of 1986, the chapter compares income-shifting behavior in 1984 and 1992 to see if the reported profitability of controlled foreign corporations (CFCs) has become more sensitive to local tax rates. Finally, it examines the relationship between excess credit expectations and the change in royalties received by the parent and reviews CFC rules that eliminate the benefits of using tax havens.

Keywords:   tax planning, multinational corporations, tax competition, tax rates, government behavior, United States, Tax Reform Act, controlled foreign corporations, excess credit, royalties

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