This paper examines the evolution of the corporate profit base and the relationship between book income and tax income for U.S. corporations over last two decades. The paper demonstrates that this relationship has broken down over the 1990s and has broken down in a manner that is consistent with increased sheltering activity. The paper traces the growing discrepancy between book and tax income associated with differential treatments of depreciation, the reporting of foreign source income, and, in particular, the changing nature of employee compensation. For the largest public companies, proceeds from option exercises equaled 27 percent of operating cash flow from 1996 to 2000 and these deductions appear to be fully utilized thereby creating the largest distinction between book and tax income. While the differential treatment of these items has historically accounted fully for the discrepancy between book and tax income, the paper demonstrates that book and tax income have diverged markedly for reasons not associated with these items during the late 1990s. In 1998, more than half of the difference between tax and book income – approximately $154.4 billion or 33.7 percent

How prevalent is long-run corporate tax avoidance? Surprisingly, there appears to be no published academic work addressing this basic question. We define tax avoidance based on the ability to sustain a cash effective tax rate (the ratio of cash taxes paid to pretax income) below the statutory tax rate. It is important to note that avoiding taxes does not imply that a firm has done anything improper. There are numerous provisions in the tax code that allow or encourage firms to reduce their taxes. We investigate the extent to which firms are able to engage in corporate tax avoidance over periods as long as ten years. We find that 437 firms, comprising 22 percent of our sample, were able to sustain a cash effective tax rate of less than 20 percent over a ten year period. An initial examination of the characteristics of successful long-run tax avoiders shows that they are spread across industries but cluster somewhat in certain industries such as oil and gas extraction, insurance, and real estate. Other characteristics associated with long-run tax avoidance include having large firm size, being incorporated in a tax haven, having high ratios of property, plant and equipment to assets, being intangible intensive, and being highly levered.

This paper examines the extent of international headquarter relocations worldwide. About 6 percent of all multinationals relocated their headquarter to another country in the 1997-2007 period. The paper presents empirical evidence on the role of tax in these relocation decisions. It considers a sample of 140 multinationals that relocated their head-quarters over the past decade and compares them to a control group of 1943 multinationals that have not done so. It is found that the additional tax due in the home country upon repatriation of foreign profits has a positive effect on the probability of relocation. The empirical results suggest that an increase in the repatriation tax by 10 percentage points would raise the share of relocating multinationals by 2.2 percentage points, equivalent to an increase in the number of relocations by more than one third. Furthermore, the introduction of controlled foreign corporation legislation also has a positive effect on the number of relocations.

This paper evaluates the possibility that a failure to exploit regulatory loopholes could result in the ousting of management. We use the U.S. hospital industry in 1985-1996 as a case study. A 1988 change in Medicare rules widened a pre-existing loophole in the Medicare payment system, presenting hospitals with an opportunity to increase operating margins by 5 or more percentage points simply by “upcoding” patients to more lucrative codes. We find that “room to upcode ” is a statistically and economically significant predictor of whether a hospital replaces its management with a new team of for-profit managers. We also find that hospitals replacing their management team subsequently upcoded more than a sample of similar hospitals that did not, as identified by propensity scores. These results suggest that managers that do not fully exploit regulatory loopholes are vulnerable to replacement.

multinationals face a different tax burden than companies that do business only in the U.S.? Do U.S. multinationals face a different tax burden from multinationals that are incorporated in other countries? These questions are important because differences in tax burden can affect where firms incorporate (i.e., establish their legal domicile) and can entice them to relocate. Answers to these questions may shed light on current policy issues, such as inver-sions and responses to the World Trade Organization. The paper reviews the extant empirical evidence related to inferences of a U.S. multinational's "tax competitiveness " and offers new evidence comparing the average tax rates of U.S. multinationals to both U.S. domes-tics and to non-U.S. multinationals. In assessing evidence related to

Abstract U.S. corporations face higher tax burdens than those in many other countries, potentially influencing merger and acquisition activity. A theoretical model of this process yields two testable implications: that, relative to high-tax domestic bidders, low-tax foreign bidders will specialize in both high profitability target firms and those with few tax deductions. I find support for both effects in the U.S. acquisition market using cross-sectional variation in target profitability and industry-level variation in deductions from bonus depreciation tax reform. Counterfactual simulations show that this reform induced a large drop in foreign acquisitions and a significant loss of aggregate wealth. * This paper previously circulated with the title "The Effects of Taxes on the Market for Corporate Control". I would like to thank Michael Smart, Robert McMillan, Laurence Booth and Alex Edwards for their guidance and support throughout this project. Thanks also to

• from the CESifo website: www.CESifo.de CESifo Working Paper No. 1013

We study associations between measures of firm value and quality and the firm’s choice of legal and regulatory environment though incorporation in an offshore financial center. Preliminary empirical results suggest that incorporation in such a jurisdiction, or switching incorporation to one, is associated with lower value as measured by Tobin’s q. This effect varies with the quality of the firm’s home country environment and the offshore domicile it selects.

Joel Slemrod for helpful comments on earlier drafts, and the American Tax Policy Institute for financial support of this research. Economic foundations of international tax rules This paper introduces “capital ownership neutrality ” (CON) and “national ownership neutrality ” (NON) as benchmarks for evaluating the desirability of international tax reforms, and applies them to analyze recent U.S. tax reform proposals. Tax systems satisfy CON if they do not distort the ownership of capital assets, which promotes global efficiency whenever the productivity of an investment differs based on its ownership. A regime in which all countries exempt foreign income from taxation satisfies CON, as does a regime in which all countries tax foreign income while providing foreign tax credits. Tax systems satisfy NON if they promote the profitability of domestic firms, and therefore home country welfare, by exempting foreign income from taxation. Standard normative benchmarks of capital export neutrality, national neutrality, and capital import neutrality carry very different implications, since they fail to account for the productivity effects of tax-induced changes in capital ownership.

School for financial support. Evaluating International Tax Reform This paper introduces “capital ownership neutrality ” (CON) and “national ownership neutrality ” (NON) as benchmarks for evaluating the desirability of international tax reforms, and applies them to analyze recent U.S. tax reform proposals. Tax systems satisfy CON if they do not distort the ownership of capital assets, which promotes global efficiency whenever the productivity of an investment differs based on its ownership. A regime in which all countries exempt foreign income from taxation satisfies CON, as does a regime in which all countries tax foreign income while providing foreign tax credits. Tax systems satisfy NON if they promote the profitability of domestic firms, and therefore home country welfare, by exempting foreign income from taxation. Standard normative benchmarks of capital export neutrality, national neutrality, and capital import neutrality carry very different implications, since they fail to account for the productivity effects of tax-induced changes in capital ownership. Proposed U.S. tax reforms that reduce the taxation of foreign income, thereby bringing the U.S. tax system more in line with the systems of other countries, have the potential to advance both American interests and global welfare.