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I. INTRODUCTION Without even considering the international taxation of business income, corporate tax reform is complex because five key structural relationships are involved: (1) the relative treatment of income earned [...], Integration of the corporate and individual income taxes can be achieved by providing shareholders a credit for corporate taxes paid with respect to corporate earnings distributed as dividends. When such integration was previously considered in the United States, proponents emphasized that it could reduce or eliminate many of the familiar distortions of a classical corporate income tax. Integration would also provide a framework for addressing current concerns for tax incentives for U.S. companies to shift income to foreign affiliates in lower-taxed countries or to expatriate in "inversion " transactions. A recent Congressional proposal for a corporate dividend deduction coupled with withholding on dividends could achieve equivalent results, while also reducing effective U.S. corporate tax rates. Keywords: corporate-personal tax integration, business tax reform, shareholder income tax, dividends, debt JEL Codes: H25, H24

I. INTRODUCTION A high U.S. corporate tax rate is not sustainable as it creates strong incentives for income shifting and expatriation. Furthermore, the pressures on the high U.S. corporate rate [...], We consider three plans for shifting the tax on corporate income to the personal level to achieve a significant reduction in the corporate tax rate. One plan eliminates the corporate tax and taxes dividends and the annual change in the value of publicly traded financial assets at ordinary rates. The second integrates corporate and shareholder taxes. The third lowers the corporate tax rate to 15 percent and taxes dividends and capital gains as ordinary income. To prevent large reductions in capital gains realizations and dividendpayouts, an interest charge on taxes deferred during the holding period would be imposed when an asset is sold. We conclude that the third alternative is more robust than the other two. Keywords: tax reform, corporate income taxation, corporate tax integration JEL codes: H24, H25, H32

This paper explores the extent to which multinational firms use internal debt as a vehicle for shifting taxable profits from high-tax to low-tax countries. While previous research has shown that [...], This paper explores the role of internal debt as a vehicle for shifting profits to low-tax countries. Using data on German multinationals, it exploits differences in taxes in more than 100 countries over l O years. The results confirm that internal debt is used more by multinationals with affiliates in low-tax countries and increases with the spread between the host-country tax rate and the lowest tax rate among all affiliates. However, tax effects are small, suggesting that profit shifting by means of internal debt is rather unimportant for German firms. Further testing indicates that this is partly due to the German controlled foreign corporation (CFC) rule. Keywords: capital structure, multinational corporations, internal debt, corporate taxation, tax planning, profit, shifting, income shifting JEL Codes: H25, G32, F23

INTRODUCTION Income earned by a multinational enterprise can be subject to double taxation if multiple tax authorities assert the right to tax the income. In particular, double taxation arises to [...], We investigate the use of bilateral advance pricing agreements (BAPAs) to resolve transfer pricing disputes between a taxpayer and two tax authorities. BAPAs are designed to protect firms from double taxation while reducing expected compliance costs. We identify settings in which we expect BAPAs to arise and investigate the effect of the program on compliance costs. We show that agreements are more likely to arise when the amount of income potentially subject to double taxation is low and the difference in tax rates between the two countries is high. We also show that the BAPA program can increase compliance costs.

The double taxation of corporate income should discourage firms from incorporating. We investigate the extent to which the aggregate allocation of assets and taxable income in the United States between corporate and noncorporate firms responds to the size of this tax distortion during the period 1959-1986. In theory, profitable firms should shift out of the corporate sector when the tax distortion is large, and conversely for firms with tax losses. Our empirical results provide strong support for these forecasts, and imply that the resulting excess burden equals 16 percent of business tax revenue. (Reprinted by permission of the publisher.)

Research is presented concerning the use of input-output theory to determine the use of deferred taxation by business enterprises in relation to the payment of dividends. The application of this theory to accounting procedures is discussed.