Income Shifting out of the United States by Foreign Multinational Firms

• 成果类型: Article; Early Access
• 署名作者: Albertus, James F.
• 署名单位: Carnegie Mellon University
• 刊物名称: REVIEW OF FINANCIAL STUDIES
• ISSN/ISSBN: 0893-9454
• DOI: 10.1093/rfs/hhaf021
• 发表日期: 2025
• 关键词: CORPORATE-TAX AVOIDANCE; financial constraints; management-practices; US MULTINATIONALS; capital structure; INVESTMENT; cash; reallocation; responses; base

摘要

I find that foreign multinational firms engage in tax-motivated income shifting out of the United States. The analysis uses novel data on foreign-owned U.S. subsidiaries as well as variation in foreign countries' tax rates and controlled foreign corporation rules. Foreign multinational firms primarily rely on tax-motivated transfer pricing to shift income out of the United States, and the aggregate amount of shifted income is modest. When foreign tax policy changes inhibit income shifting, foreign-owned U.S. subsidiaries' investment and employment fall. The results indicate that the U.S. economy has limited exposure to tax policies set abroad through foreign direct investment in the United States.