Essays on the Responses to Taxation by US Firms

Business taxation, by affecting the costs of certain behaviors of firms, owners, or their counterparties, can trigger potentially substantial changes in real activity, such as changes in inputs or production processes. But it can also prompt avoidance responses---such as legal restructuring or changes in tax reporting---that may have important effects on efficiency and distribution. Understanding such responses is thus critical for enacting efficient and well-informed tax policy./nIn this dissertation I investigate the real and avoidance responses at the intersection of several important topics in businesses taxation, namely capital taxation, taxation of passthrough entities, international taxation, and corporate taxation. My research sheds new light on our understanding of US business taxation by employing a variety of empirical methods to (1) develop new explanations for persistent puzzles in the literature, (2) fill knowledge gaps in the current body of business tax research, and (3) draw attention to new issues that have so far received little attention by public finance economists./nIn Chapter 1, I investigate financing and investment responses by corporations to a change in capital taxation, presenting results that help resolve an existing conflict among empirical findings in the public finance literature. I estimate that dividend taxes, by impacting the cost of equity financing, have large effects on the financing, investment, and real outcomes of many US public firms. But---in contrast with economists' longstanding focus on capital investment outcomes---I find these responses are mostly from smaller, cash-constrained firms through “non-capital” investment channels: R&D and operating expenditures. Exploiting a quasi-experiment that tracks financing and expenditure responses to the 2003 dividend tax cut, I estimate a large, immediate, and sustained increase in average equity financing (+86% ± 11%) by these firms, reflecting a high elasticity to the cost of capital. Responsive firms put the cash substantially toward operating expenditures and R&D, rather than tangible investment. I also find higher job growth and long-run sales among the responsive firms. These results make sense, reconciling mixed evidence in recent research: because dividend taxes affect the cost of equity financing, the firms impacted most are those that actually rely on equity financing---smaller, often unprofitable, less capital-intensive firms who invest heavily in "non-capital" pathways./nIn Chapter 2, I describe and estimate tax avoidance behavior that uses complex entity structures involving partnerships and tax havens to exploit discrepancies in tax treatment of capital income across jurisdictions. I also address a significant missing piece of knowledge in the public finance literature: where partnership income goes. Partnerships are the fastest growing class of business entity in the United States and represent over one third of reported business income, but due to their legal complexity, data quality, and opaque nature economists have not yet been able to identify where a sizeable portion of this income goes. In this paper, I use US federal tax records from 2005-2019 to compile a comprehensive analysis covering 99% of the income flowing to the owners of partnerships. I find that a much larger portion goes to foreign owners than previously thought, and that most of this amount goes to tax havens---over $1 trillion since 2011. The majority of these flows likely face zero tax in either the US or in the tax haven. The evidence I present suggests a prevalent use of entity arrangements by investment firms that shield investors from tax and reporting through "blocker structures," predominantly in the Cayman Islands. Evidence also suggests a substantial increase in income reported after the enactment of Foreign Account Tax Compliance Act (FATCA)./nIn Chapter 3, I investigate the degree to which corporations can manipulate their accounting of expenses to avoid taxes, and what effects this has on the corporate tax base. The investigation exploits a unique corporate tax reform in Texas that replaced a 4.5% profits tax with a broader 1% gross revenue tax and that eliminated almost all deductions, but still permitted corporations to deduct one of two categories of expenses: cost of goods sold (COGS) or total worker compensation. Data from federal corporate income tax returns makes it possible to estimate the effects of the reform, as data are consistent across years and harmonized across states. Strong evidence reveals a very large avoidance response for COGS but not for compensation: corporations reduced the tax base roughly 4% by reclassifying non-deductible expenses into COGS (with a large elasticity of roughly -5 ± 1), but there is little reclassification into compensation. These findings reveal the potentially very large but also highly context-specific nature of accounting reclassification responses. Given that numerous states have some form of gross receipts tax and that there is currently wide discussion of measures to broaden corporate tax bases by incorporating accounting measures, these findings offer important considerations for policymakers and tax authorities when designing, scoring, and enforcing corporate tax changes.

Advisor: Auerbach, Alan