Corporate Income Taxation in the Digital Age: Africa in the Corporate Tax Haven Index 2019

Author(s):  
Rachel Etter-Phoya ◽  
Shanna Lima ◽  
Markus Meinzer
2001 ◽  
Vol 39 (3) ◽  
pp. 800-838 ◽  
Author(s):  
Thomas A Gresik

Financial and real investment flexibility, tax competition, and superior economic information by transnationals both create a rationale for corporate income taxation and limit the effectiveness of such taxation. While these factors have led to a variety of transnational tax policies, such as deferral, double taxation, apportionment, and trade rules, very few of these institutional features have been integrated into tax competition and agency models. In this paper, I show how the integration of investment flexibility, tax competition, and agency issues is crucial to our understanding of corporate tax policies.


2013 ◽  
Author(s):  
Michael Lang ◽  
Claus Staringer ◽  
Alfred Storck ◽  
Pasquale Pistone ◽  
Josef Schuch

2014 ◽  
Vol 12 (1) ◽  
pp. 17-40 ◽  
Author(s):  
Thomas D. Schultz ◽  
Kyle Scott

ABSTRACT We examine the taxation of corporate income earned in the Commonwealth of Puerto Rico and how the repeal of the possession tax credit available under Internal Revenue Code (IRC) §936 resulted in many U.S. companies converting former possessions corporations into controlled foreign corporations. Although Puerto Rico is a U.S. territory, the conversions highlight that corporations organized under the laws of the Commonwealth generally are foreign corporations for U.S. tax purposes. A U.S. Senate Subcommittee reports Microsoft Corporation shifted offshore the recognition of nearly one-half of its U.S. net retail sales revenue for the period 2009–2011 by transferring intellectual property rights to a controlled subsidiary in Puerto Rico. We find that the corresponding U.S. tax benefits are significant compared to the credits once claimed under IRC §936, and over 20 percent of Standard & Poor's (S&P) 500 firms were in a similar position to avoid federal taxation by shifting income between political subdivisions of the United States.


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