Determinants of the Choice Between Partial and Comprehensive Income Tax Allocation: The Case of the Domestic International Sales Corporation

This study examines several potential explanations for managers' choice between comprehensive and partial income tax allocation related to the indefinite deferral of income taxes allowed for Domestic International Sales Corporations (DISCs). Results from a sample of 320 firms with DISCs operational in 1972-74 are consistent with managers acting opportunistically to avoid debt covenant violations, political scrutiny, or to mask poor performance, even after controlling for firms' economic expectations and investment opportunity sets. In addition, a strong association is observed between external auditors' stated positions on the tax allocation issue and their client firms' method choice, a relatively new result in the literature.