Julie H. Collins

Foreign Tax Credit Limitations And Preferred Stock Issuances

This paper documents a consequence of a subset of tax law changes enacted in the Tax Reform Act of 1986 applicable to U.S. multinational corporations. Specifically, we provide evidence that the more stringent interest allocation rules and foreign tax credit limitations enacted in the 1986 Act resulted in the increased use of preferred stock as a financing instrument for U.S. multinationals. By decreasing the tax-favored status of debt for multinationals, Congress provided incentives for issuances of an alternative financing instrument, preferred stock. The cost of capital for multinational firms is a function of their total tax burden consisting of both domestic and foreign taxes. The United States taxes the worldwide income of U.S.-based multinational corporations. In addition, U.S. multinationals pay taxes in foreign jurisdictions based on the tax rules of the foreign governments. The U.S. mitigates, but does not eliminate, multiple taxation of foreign income

Corporate domicile and average effective tax rates: The cases of Canada, Japan, the United Kingdom, and the United States

We use financial statement information to estimate three alterantive average effective tax rates for firms domiciled in Canada, Japan, the United Kingdom, and the United States during the period 1982 to 1991. While many of the firms we examine operate worldwide, we use the termdomicile to refer to the legal residence or site of incorporation of the parent company. Our objective is to determine themarginal impact of a companys domicile on its worldwide tax burden, with controls for industry and year. We find both among domestic-only companies and among multinational companies the domiciles are consistently ranked in descending order by average effective tax rates as Japan, the United Kingdom, the United States, and Canada. In comparing domestic-only companies and multinationals domiciled in the same jurisdiction, only U.S. multinationals consistently face a greater tax burden than their domestic counterparts.

Does Acquistion by Non-U.S. Shareholders Cause U.S. Firms to Pay Less Tax?

A battery includes a battery case, an electrode assembly, positive and negative electrode collectors, a sealing body, an external terminal, a conducting member, a deforming plate, and a first insulating member. The positive or negative electrode collector has a base portion facing the first insulating member, and a lead portion connected to the electrode assembly. A fixing portion fixing the base portion and the first insulating member to each other is provided in the first insulating member. The fixing portion is located nearer to the connection portion between the deforming plate and the positive or negative electrode collector than the sealing body side support position of the first insulating member. The outer peripheral edge of the electrode assembly side surface of the first insulating member is provided with a rib protruding to the electrode assembly side and extending along the outer peripheral edge of the base portion.