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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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    1. Hines Jr., James R., 2010. "Income misattribution under formula apportionment," European Economic Review, Elsevier, vol. 54(1), pages 108-120, January.
    2. Clausing, Kimberly A., 2003. "Tax-motivated transfer pricing and US intrafirm trade prices," Journal of Public Economics, Elsevier, vol. 87(9-10), pages 2207-2223, September.
    3. Rosanne Altshuler, 2000. "Recent Developments in the Debate on Deferral," Departmental Working Papers 200013, Rutgers University, Department of Economics.
    4. Mihir A. Desai, 2003. "The Divergence between Book Income and Tax Income," NBER Chapters, in: Tax Policy and the Economy, Volume 17, pages 169-208, National Bureau of Economic Research, Inc.
    5. Mihir A. Desai, 2005. "The Degradation of Reported Corporate Profits," Journal of Economic Perspectives, American Economic Association, vol. 19(4), pages 171-192, Fall.
    6. Douglas Shackelford & Joel Slemrod, 1998. "The Revenue Consequences of Using Formula Apportionment to Calculate U.S. and Foreign-Source Income: A Firm-Level Analysis," International Tax and Public Finance, Springer;International Institute of Public Finance, vol. 5(1), pages 41-59, February.
    7. Ruud A. de Mooij & Sjef Ederveen, 2008. "Corporate tax elasticities: a reader's guide to empirical findings," Oxford Review of Economic Policy, Oxford University Press and Oxford Review of Economic Policy Limited, vol. 24(4), pages 680-697, winter.
    8. de Mooij, Ruud A & Ederveen, Sjef, 2003. "Taxation and Foreign Direct Investment: A Synthesis of Empirical Research," International Tax and Public Finance, Springer;International Institute of Public Finance, vol. 10(6), pages 673-693, November.
    9. Rosanne Altshuler & Harry Grubert, 2005. "The Three Parties in the Race to the Bottom: Host Governments, Home Governments and Multinational Companies," CESifo Working Paper Series 1613, CESifo.
    10. Clausing, Kimberly A., 2009. "Multinational Firm Tax Avoidance and Tax Policy," National Tax Journal, National Tax Association;National Tax Journal, vol. 62(4), pages 703-725, December.
    11. Clausing, Kimberly A., 2006. "International Tax Avoidance and U.S. International Trade," National Tax Journal, National Tax Association;National Tax Journal, vol. 59(2), pages 269-287, June.
    12. Ruud Mooij, 2005. "Will Corporate Income Taxation Survive?," De Economist, Springer, vol. 153(3), pages 277-301, September.
    13. Clemens Fuest & Thomas Hemmelgarn & Fred Ramb, 2007. "How would the introduction of an EU-wide formula apportionment affect the distribution and size of the corporate tax base? An analysis based on German multinationals," International Tax and Public Finance, Springer;International Institute of Public Finance, vol. 14(5), pages 605-626, October.
    14. Michael P. Devereux & Simon Loretz, 2008. "The Effects of EU Formula Apportionment on Corporate Tax Revenues," Fiscal Studies, Institute for Fiscal Studies, vol. 29(1), pages 1-33, March.
    15. Michael P Devereux & Simon Loretz, 2008. "Increased efficiency through consolidation and formula apportionment in the European Union?," Working Papers 0812, Oxford University Centre for Business Taxation.
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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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