This paper provides estimates of the amount of income shifted across n
ational borders within the manufacturing operations of US multinationa
l corporations (MNCs) in 1988. It is assumed that each MNC arranges it
s investments such that, after accounting for income shifting opportun
ities, the after-tax rate of return on a marginal investment is the sa
me for all its affiliates, regardless of location. The income shifting
is then inferred by comparing shares of after-tax profits, assets and
sales of the affiliated members. It is estimated that such shifting a
mounted to about $8 billion (on net), which is less than 4% of the wor
ldwide taxable income of the manufacturing MNCs.