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Tax-Haven Incorporation for U.S.-Headquartered Firms: No Exodus Yet

Eric J. Allen and Susan C. Morse

National Tax Journal, 2013, vol. 66, issue 2, 395-420

Abstract: U.S. income tax rules may encourage a U.S.-headquartered multinational corporation (MNC) to adopt a structure with a tax haven parent. We study data from firms that conducted initial public offerings in the United States between 1997 and 2010 and offer evidence that U.S.-headquartered MNCs rarely incorporate in tax havens. Of the 918 U.S.-headquartered MNCs that we identify, only 27 are incorporated in tax havens. Others have pointed to the recent increase in the proportion of firms conducting U.S. IPOs that incorporate in tax havens as possible evidence that more U.S.-headquartered MNCs make this decision. We show instead that Chineseheadquartered firms drive this increase.

Date: 2013
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