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Journal Article
The Impact of the 2017 Tax Cuts and Jobs Act on U.S. Multinationals' Intangible Assets
This article investigates the impact of the 2017 Tax Cuts and Jobs Act (TCJA) on the intangibles of U.S. multinationals. We develop a theoretical model that incorporates key provisions of the TCJA—Global Intangible Low-Taxed Income (GILTI) and Foreign-Derived Intangible Income (FDII)—and derive testable implications for changes in licensing and patent transfer patterns. Using data on international royalty flows and patent assignments, we test the model’s predictions. Our findings suggest that the TCJA may have impacted profit-shifting strategies through intangibles, aligning with our ...
Working Paper
Occupational Licensing and Occupational Mobility
This paper estimates the impact of occupational licensing at the extensive margin (existence) and intensive margin (qualifications) on the occupational mobility of US workers. Using 2015–2022 Current Population Survey data on worker occupational choices matched to licensing-policy data, I show that the existence of licensing regulation significantly reduces the probability that a worker enters an occupation. This reduced mobility is largely due to licensing fees and minimum thresholds for age and education. This finding may help explain the weak relationship between licensure and product ...
Working Paper
Taxation and the Global Allocation of Intangibles
We study how international tax regimes and intellectual property (IP) rights shape the global allocation of intangible assets. Using a new dataset of cross-border patent transactions, we find that tax differentials are a key determinant of intra-firm transfers within multinational companies. Stronger IP rights play a bigger role in inter-firm transactions. To interpret these patterns, we develop a model in which firms choose to license, sell, or profit-shift patents depending on tax wedges and differences in IP protection. The theory rationalizes these findings and highlights how differences ...
Working Paper
Taxation and the Global Allocation of Intangibles
We study how international tax regimes affect the allocation of intangible assets using a new dataset on global patent transfers and a structural model of shifting decisions. Empirically, patent transfers respond strongly to statutory tax differentials during 2007–2012 but much less after major reforms. In the model, heterogeneous patents choose between licensing and shifting based on tax wedges and setup costs. Calibrated to observed shifting rates, the model matches the concentration of royalty income in low-tax jurisdictions. Counterfactuals show that harmonizing tax rates greatly ...