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Corporate tax payments under formulary apportionment: Evidence from the financial reports of 50 major U.S. multinational firms

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  • Clausing, Kimberly A.
  • Lahav, Yaron

Abstract

Under a formulary apportionment system of taxing multinational corporate income, U.S. tax liabilities would be based on the product of a multinational firm's worldwide income and the fraction of their real activities that occur in the United States – typically, an average of asset, payroll, and sales shares. This analysis utilizes financial reporting data for 50 large U.S. multinational firms to analyze how tax payments would change under a possible formulary system, updating Shackelford and Slemrod (1998). Our time period is 2005–2007 instead of 1989–1993. We find that tax payments under formulary apportionment would increase modestly overall but by a lower magnitude than found by Shackelford and Slemrod. Given the changes in the international tax environment since the earlier time period, this is a puzzling finding; we speculate regarding possible explanations.

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  • Clausing, Kimberly A. & Lahav, Yaron, 2011. "Corporate tax payments under formulary apportionment: Evidence from the financial reports of 50 major U.S. multinational firms," Journal of International Accounting, Auditing and Taxation, Elsevier, vol. 20(2), pages 97-105.
    • Handle: RePEc:eee:jiaata:v:20:y:2011:i:2:p:97-105
    DOI: 10.1016/j.intaccaudtax.2011.06.004
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    References listed on IDEAS

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    Cited by:

    1. Ruud De Mooij & Li Liu & Dinar Prihardini, 2021. "An Assessment of Global Formula Apportionment," National Tax Journal, University of Chicago Press, vol. 74(2), pages 431-465.
    2. Tommaso Faccio & Roberto Iacono, 2022. "Corporate Income Taxation and Inequality: Review and Discussion of Issues Raised in The triumph of injustice—How the rich dodge taxes and how to make them pay (2019)," Review of Income and Wealth, International Association for Research in Income and Wealth, vol. 68(3), pages 819-829, September.
    3. Eichfelder, Sebastian & Hechtner, Frank & Hundsdoerfer, Jochen, 2015. "Formula apportionment: Factor allocation and tax avoidance," arqus Discussion Papers in Quantitative Tax Research 199, arqus - Arbeitskreis Quantitative Steuerlehre.
    4. Barrios, Salvador & d'Andria, Diego & Gesualdo, Maria, 2020. "Reducing tax compliance costs through corporate tax base harmonization in the European Union," Journal of International Accounting, Auditing and Taxation, Elsevier, vol. 41(C).
    5. Tommaso Faccio & Valpy Fitzgerald, . "Sharing the corporate tax base: equitable taxing of multinationals and the choice of formulary apportionment," UNCTAD Transnational Corporations Journal, United Nations Conference on Trade and Development.
    6. Eichfelder, Sebastian & Hechtner, Frank & Hundsdoerfer, Jochen, 2015. "Formula apportionment: Factor allocation and tax avoidance," Discussion Papers 2015/30, Free University Berlin, School of Business & Economics.
    7. Johannes Becker, 2024. "Rationalizing Formula Apportionment," CESifo Working Paper Series 11234, CESifo.

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