University of California, Hastings College of the Law UC Hastings Scholarship Repository Faculty Scholarship 2013 Tax-Haven Incorporation for U.S.-Headquartered Firms: No Exodus Yet Susan C. Morse UC Hastings College of the Law,
[email protected] Eric J. Allen Follow this and additional works at: https://repository.uchastings.edu/faculty_scholarship Recommended Citation Susan C. Morse and Eric J. Allen, Tax-Haven Incorporation for U.S.-Headquartered Firms: No Exodus Yet, 66 Nat'l Tax J. 395 (2013). Available at: https://repository.uchastings.edu/faculty_scholarship/1431 This Article is brought to you for free and open access by UC Hastings Scholarship Repository. It has been accepted for inclusion in Faculty Scholarship by an authorized administrator of UC Hastings Scholarship Repository. For more information, please contact
[email protected]. National Tax Journal, June 2013, 66 (2), 395–420 TAX-HAVEN INCORPORATION FOR U.S.-HEADQUARTERED FIRMS: NO EXODUS YET Eric J. Allen and Susan C. Morse U.S. income tax rules may encourage a U.S.-headquartered multinational corpora- tion (MNC) to adopt a structure with a tax haven parent. We study data from fi rms that conducted initial public offerings in the United States between 1997 and 2010 and offer evidence that U.S.-headquartered MNCs rarely incorporate in tax havens. Of the 918 U.S.-headquartered MNCs that we identify, only 27 are incorporated in tax havens. Others have pointed to the recent increase in the proportion of fi rms conducting U.S. IPOs that incorporate in tax havens as possible evidence that more U.S.-headquartered MNCs make this decision.