Suchergebnisse

This paper is focused on the options for reducing the U.S. fiscal deficit in the aftermath of the financial crisis. The first part of the paper is devoted to an assessment of the economic outlook and the impact of the financial crisis on the medium-term fiscal balance of the federal government. Is there a short-term trade-off between the need for further fiscal stimulus and deficit reduction and how should it be managed? The second part of the paper examines the options for fiscal consolidation on both the expenditure and revenue sides of the budget.

Most studies of tax competition and the race to the bottom focus on potential host countries competing for mobile capital, neglecting the role of corporate tax planning and of home governments that facilitate this planning. This neglect in part reflects the narrow view frequently taken of the policy instruments that countries have available in tax competition. But high-tax host governments can, for example, permit income to be shifted out to tax havens as a way of attracting mobile companies. Home countries will cooperate in this shift if their companies? gain is greater than any reduction in the domestic tax base. We use various types of U.S. data, including firm level tax files, to identify the role of the three parties (host governments, home governments and MNCs) in the evolution of tax burdens on U.S. companies abroad from 1992 to 2002. This period is of particular interest because the United States introduced regulations in 1997 that greatly simplified the use of more aggressive tax planning techniques. The evidence indicates that from 1992 to 1998 the decline in effective tax rates on U.S. companies was driven largely by host governments defending their market share. But after 1998, tax avoidance behavior seems much more important. One indication is that effective tax rates on U.S. companies had a much weaker link with local statutory tax rates. After 1997, the new regulations motivated a very large growth in intercompany payments and a parallel growth of holding company income abroad. We attempt to estimate how many of these payments were deductible in the host country, and conclude that by 2002 the companies were saving about $7.0 billion per year by using the more aggressive planning strategies. This amounts to about 4 percent of companies? foreign direct investment income and about 15 percent of their foreign tax burden.

Most studies of tax competition and the race to the bottom focus on potential host countries competing for mobile capital, neglecting the role of corporate tax planning and of home governments that facilitate this planning. This neglect in part reflects the narrow view frequently taken of the policy instruments that countries have available in tax competition. For example, high-tax host governments can permit income to be shifted out to tax havens as a way of attracting mobile companies. Home countries will cooperate in this shift if they think the benefit to their companies is greater than any reduction in the domestic tax base. We use various types of U.S. data, including firm level tax files, to identify the role of the three parties (host governments, home governments and MNCs) in the evolution of tax burdens on U.S. companies abroad from1992 to 2002. This period is of particular interest because the United States introduced regulations in 1997 that greatly simplified the use of more aggressive tax planning techniques. The evidence indicates that from 1992 to 1998 the decline in effective tax rates on U.S. companies was driven largely by host governments defending their market share. But after 1998, tax avoidance behavior seems much more important. Effective tax rates on U.S. companies had a much weaker link with local statutory tax rates. Furthermore, the disparity in the reported profitability of subsidiaries in high-tax and low-tax jurisdictions grew substantially. After 1997, there was a very large growth in intercompany payments and a parallel growth of holding company income. We attempt to estimate how much of these payments were deductible in the host country, and conclude that by 2002 the companies were saving about $7.0 billion per year by using the more aggressive planning strategies. This amounts to about 4 percent of foreign direct investment income and about 15 percent of their foreign tax burden.

We use information from the tax returns of U.S. multinational corporations to address three questions related to tax competition. First, does tax competition or company tax planning behavior better explain recent decreases in the local effective tax rates faced by U.S. multinationals investing abroad? Second, have countries become more aggressive in their use of tax concessions to attract particular types of foreign capital? And finally, has the role of taxes in the location decisions of U.S. manufacturers increased in recent years? Between 1992 and 2000, the average effective tax rate faced by U.S. manufacturers on income earned abroad fell from 25 percent to 21 percent. Our results suggest that the evolution of country effective tax rates between 1992 and 1998 seems to be driven by tax competition. Countries that lost shares of U.S. manufacturing real capital prior to 1992 cut their rates the most over this period. However, the most recent data suggests that companies may not need tax competition to lower effective tax burdens abroad. The evolution of country effective rates between 1998 and 2000 seems to be driven by company rather than country behavior. This is consistent with the introduction of the ?check the box? regulations in 1997 which made it easier for corporations to use ?self-help? to lower tax burdens. Interestingly, we find that countries were rewarding more mobile companies and those that were perceived to be more beneficial to the local economy with tax concessions as far back as 1984. Finally, although not conclusive, our empirical work suggests that U.S. manufacturers may have become more sensitive to differences in local tax rates across countries in recent years.

This paper contributes to the small empirical literature that attempts to estimate tax reaction functions of national governments competing with other national governments. After presenting a simple theoretical model, we estimate reaction functions for European countries for a pure Nash model and for a model in which the U.S. can act as a Stackelberg leader while the European countries compete with each other in a Nash way. We initially find a positive Nash reaction function for European countries with respect to capital taxes, but no reaction with respect to labor taxes. Further investigation of the capital tax response results in our main finding, that the European countries behave as if the U.S. is a Stackelberg leader in setting corporate taxes after the U.S. 1986 Tax Reform Act but not before. We also test whether Germany or the United Kingdom played a leadership role and find that they did not. These regression results are reinforced by our Granger causality tests, and are somewhat stronger when we exclude certain tax havens. Over time, European countries seem to have become more intensely competitive with the U.S. in corporate taxes, but less intensely competitive among themselves.