Howard Godfrey, Ph., D. and Jack Cathey, Ph., D. Accounting, University of North Carolina at Charlotte, Belk College of Business, Charlotte, NC 28223
International business operations have been growing rapidly in recent decades. The U.S. has higher income tax rates than much of the rest of the world. One important goal of global tax management is to have income subject to tax in countries with low income tax rates. A second objective is to avoid double taxation of earnings, which happens when the same income is taxed in two different countries.
The amount of income paid to the United States by a multinational corporation located in the U.S. can be affected by:
- Transfer pricing for goods, services and technology in transactions between a U.S. corporation and a related corporation in another country.
- Earnings stripped out of the U.S. tax system through interest on intercompany debt that is paid to a related corporation in a lower tax jurisdiction.
- U.S. corporate expansion into low-tax rate jurisdictions through investments in foreign subsidiaries (or transfer of existing U.S. operations to such foreign countries). Payment of U.S. income tax on those foreign earnings may be deferred by avoiding repatriation of the earnings to the U.S. This is referred to as tax deferral, because U.S. income tax will apply if earnings are repatriated in the future.
This paper analyzes the latest statistics reported by the Internal Revenue Service from tax returns filed by multinational corporations. The purpose is to see the extent to which the statistics provide insight into current global tax management practices.