Tax Administration: Comparison of the Report Tax Liabilities of Foreign- and U. S. -Controlled Corporations, 1998-2005

James R. White

Jan 2009 · DIANE Publishing

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Concerns about transfer pricing abuse have led researchers to compare the tax liabilities of foreign- and U.S.-controlled corp. (Transfer prices are the prices related co. charge on inter-co. transactions.) However, such comparisons are complicated because other factors may explain the differences in reported tax liabilities. Three prior reports found differences in the percentages of foreign-controlled and U.S.-controlled corp. reporting no tax liability. This report updates the previous reports by comparing: (1) the tax liabilities of foreign-controlled domestic corp. (FCDC) and U.S.-controlled corp. (USCC) -- including those reporting zero tax liabilities for 1998 through 2005: and (2) characteristics of FCDCs and USCCs such as age, size, and industry. Charts.