The Effective Tax Rates of U.S. Firms with Permanent Deferral

2 Pages Posted: 17 Jun 2015


This article calculates the effective tax rate (ETR) of U.S. corporate multinationals. It takes into account the permanent deferral of corporate taxation of foreign earnings held in controlled foreign corporations designated as permanently reinvested earnings (PRE) and recurring tax holidays presumed to occur once every 10 years, similar to the American Jobs Creation Act of 2004 (AJCA). The results are presented here as a sensitivity analysis of PRE taken as a percentage of total unexplained book tax differences in the following table.

Suggested Citation

Bogenschneider, Bret, The Effective Tax Rates of U.S. Firms with Permanent Deferral. Tax Notes, Vol. 145, No. 12, 2014. Available at SSRN:

Bret Bogenschneider (Contact Author)

University of Surrey - School of Law ( email )

United Kingdom

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