H. Grubert et J. Mutti, INTERNATIONAL ASPECTS OF CORPORATE-TAX INTEGRATION - THE CONTRASTING ROLE OF DEBT AND EQUITY FLOWS, National tax journal, 47(1), 1994, pp. 111-133
We analyze various corporate tax integration plans in an international
simulation model of the United States and the rest of the world. The
schemes considered include ''backward'' integration in which interest
and dividends are not deductible at the corporate level and are exempt
at the shareholder level. We distinguish between debt and equity flow
s, because integration often has opposite effects on them. Such offset
ting effects are one reason full integration and dividend credit propo
sals have a small effect on international net investment positions. Ne
vertheless, if integration benefits are denied to foreigners, the lowe
r net investment income foreigners receive can have significant effect
s on the long-run trade balance and sectoral outputs. These results di
ffer from a closed-economy outcome, because higher United States incom
e shifts output to nontraded goods, whose output would otherwise decli
ne because of a larger noncorporate component. They also differ from a
small open economy in which the cost of capital does not decline in t
he corporate sector. The results also contrast with an all-equity mode
l in which an outflow of equity is not offset by an inflow of debt. Ba
ckward integration causes a large capital outflow, because foreigners
derive no benefit if interest income is exempt from personal-level tax
. As a result of the importance of debt, we also find, paradoxically,
that an across-the-board increase in capital taxes may lead to a capit
al inflow.