In this paper we examine whether, under pre-2018 tax law, a global firm reported a lower income tax expense simply because its publicly traded parent was incorporated outside the United States. Our study considers loss years as well as profit years and isolates the effect of the incorporation location of the parent by considering only U.S. and non-U.S. multi-national companies (MNCs) with a significant U.S. presence. We find that, in profit years, U.S. firms show an effective tax rate that is greater by 5 percentage points compared to non-U.S. firms. Conversely, in loss years, which make up approximately 30% of our sample, U.S. firms have better tax results, which can be expressed as an effective tax rate advantage of 4 percentage points among firms that do not record a valuation allowance. Our study demonstrates that the relative tax cost of organizing as a U.S. firm is smaller than some have suggested, and reinforces the importance of considering loss year results when evaluating tax policies. The results also suggest that the reduction in the U.S. corporate income tax rate under the 2017 Tax Cuts and Jobs Act, or TCJA, will provide smaller benefits to U.S.-parented corporations when loss years are also considered.
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13 December 2019
Research Article|
December 13 2019
Does Parenting Matter? U.S. Parents, Non-U.S. Parents, and Global Firm Taxes
Eric J. Allen;
Eric J. Allen
Leventhal School of Accounting,
University of Southern California
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Susan C. Morse
*
This paper has benefitted greatly from the comments of Patricia Dechow, Dain Donelson, David Erkens, Shane Heitzman, Calvin Johnson, Edward Kleinbard, Clive Lennox, Kevin Markle, Lillian Mills, Chuck Swenson, and participants at the: UNC tax Symposium, USC CLASS workshop, USC/UCI/UCI Accounting Symposium, National Tax Associate annual meeting, Tulane University Tax Roundtable and Georgetown University Tax Law and Public Finance Workshop. All errors are our own.
Online ISSN: 2380-5013
Print ISSN: 2380-5005
© 2019 E. J. Allen and S. C. Morse
2019
E. J. Allen and S. C. Morse
Licensed re-use rights only
Journal of Law, Finance and Accounting (2019) 4 (2): 239–290.
Citation
Allen EJ, Morse SC (2019), "Does Parenting Matter? U.S. Parents, Non-U.S. Parents, and Global Firm Taxes". Journal of Law, Finance and Accounting, Vol. 4 No. 2 pp. 239–290, doi: https://doi.org/10.1561/108.00000038
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