The United States tax code allows multinational corporations to credit
tax payments made to foreign treasuries against domestic tax obligati
ons, up to their United States tax liability on foreign-source income.
If foreign tax payments exceed the United States tax liability on for
eign-source income, the corporation is said to be in excess credits. W
e study how the incentives for investment abroad through foreign subsi
diaries change as parent corporations transit into and out of excess c
redits. We also examine how the presence of foreign tax credit carry-f
orwards affects tax-related investment incentives.