Tax Haven Incorporation for U.S. Headquartered Firms: No Exodus Yet
Eric J. Allen
University of Southern California - Leventhal School of Accounting
Susan C. Morse
University of California Hastings College of the Law
December 20, 2012
National Tax Journal, 66, 2013, Forthcoming
U.S. income tax rules may encourage a U.S.-headquartered multinational corporation (“MNC”) to adopt a tax-haven-parented structure. We study data from firms that conducted initial public offerings in the United States between 1997 and 2010 and offer evidence that U.S.-headquartered MNCs rarely incorporate in tax havens. Of the 918 U.S.-headquartered MNCs that we identify, only 27 are incorporated in tax havens. Others have pointed to the recent increase in the proportion of firms conducting U.S. IPOs that incorporate in tax havens as possible evidence that U.S.-headquartered MNCs increasingly make this decision. We show instead that Chinese-headquartered firms drive this increase. We list the U.S.-headquartered firms that we find have incorporated in tax havens and offer some analysis and ideas for further research.
Number of Pages in PDF File: 39
Keywords: international taxation, initial public offerings, tax havens, headquarters, incorporation
JEL Classification: H25Accepted Paper Series
Date posted: October 28, 2011 ; Last revised: May 15, 2013
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