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As American as Apple Inc.: International Tax and Ownership Nationality

68 Pages Posted: 11 Feb 2014 Last revised: 21 Jul 2015

Chris William Sanchirico

University of Pennsylvania Law School; University of Pennsylvania Wharton School - Business Economics and Public Policy Department

Date Written: October 28, 2014

Abstract

The ownership nationality of large US multinational companies plays an implicit but important role in the current debate over how such companies should be taxed. This paper identifies that role and investigates what is actually known about where these companies’ shareholders reside.

Keywords: Ownership nationality, home country bias, home equity bias, home bias, TIC system, CPIS, institutional investment managers, Section 13(f), Investment Company Act, Investment Advisers Act, Forms 13F, N-CSR, N-Q, ADV, PF, 1042-S

JEL Classification: K34, K22, K33, H24, H22, H25, H87, E62, F2, F3, F36, F4, F42, G23, G24, G28, G38

Suggested Citation

Sanchirico, Chris William, As American as Apple Inc.: International Tax and Ownership Nationality (October 28, 2014). Tax Law Review, Vol. 68, No. 2, 2015, pp. 207-274; U of Penn Law School, Public Law Research Paper No. 14-5; U of Penn, Inst for Law & Econ Research Paper No. 14-3. Available at SSRN: https://ssrn.com/abstract=2394227 or http://dx.doi.org/10.2139/ssrn.2394227

Chris William Sanchirico (Contact Author)

University of Pennsylvania Law School ( email )

3501 Sansom Street
Philadelphia, PA 19104
United States
215-898-4220 (Phone)

HOME PAGE: http://www.law.upenn.edu/faculty/csanchir/

University of Pennsylvania Wharton School - Business Economics and Public Policy Department

3641 Locust Walk
Philadelphia, PA 19104-6372
United States

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