Search Results
Transfer Pricing of Intangible Assets: Evidence from Patent Data
To reduce their tax exposure, multinationals may seek to shift profits to countries with lower tax rates. Do patents play a role in this strategy?
Profit Shifting in the 21st Century: Multinationals’ Use of Intrafirm Patent Transfers
An analysis indicates that a high percentage of U.S. patents that shifted to tax havens like Bermuda are intrafirm transfers. Such transfers may be a tax avoidance strategy by multinationals.
The Puzzle of Multinationals’ Profits: Why Tax Havens Yield Higher Returns
An analysis examines how U.S. multinationals’ tax and profit-shifting strategies might affect yields on direct investment in tax havens versus G7 economies.
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 ...