Income Shifting in U.S. Multinational Corporations

David Harris, Randall Morck, Joel Slemrod, Bernard Yeung

NBER Working Paper No. 3924
Issued in December 1991
NBER Program(s):   PE

It is often claimed that multinational firms avoid taxes by shifting income from high-tax to low-tax countries. Using a five year panel of data for two hundred large U.S. manufacturing firms, we find that U.S. tax liability, as a fraction either of U.S. sales or U.S. assets, is related to the location of foreign subsidiaries in a way that is consistent with tax-motivated income shifting. Having a subsidiary in a tax haven, Ireland, or one of the "four dragon" Asian countries - all characterized by low tax rates - is associated with lower U.S. tax ratios. Having a subsidiary in a high-tax region is associated with higher U.S. tax ratios. These results suggest that U.S. manufacturing companies shift income out of high-tax countries into the U.S., and from the U.S. to low-tax countries. Such behavior certainly lowers worldwide tax liabilities for larger U.S. manufacturing companies and appears to significantly lower their U.S. tax liabilities as well.

(379 K)

(261 K)

Published:

• Studies in Internatioanl Taxationedited by Alberto Giovannini, R. Glenn Hubbard, and Joel Slemrod University of Chicago Press: May 1993 ,
• Income Shifting in U.S. Multinational Corporations, David Harris, Randall Morck, Joel B. Slemrod, in Studies in International Taxation (1993), University of Chicago Press
  

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