Tax Administration: Comparison of the Reported Tax Liabilities of Foreign- and U.S.-Controlled Corporations, 1998-2005
Published: 2008-07-24T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: Concerns about transfer pricing abuse have led researchers to compare the tax liabilities of foreign- and U.S.-controlled corporations. (Transfer prices are the prices related companies charge on intercompany transactions.) However, such comparisons are complicated because other factors may explain the differences in reported tax liabilities. In three prior reports, GAO found differences in the percentages of foreign-controlled and U.S.-controlled corporations reporting no tax liability. GAO was asked to update the previous reports by comparing: (1) the tax liabilities of foreign-controlled domestic corporations (FCDC) and U.S.-controlled corporations (USCC)-including those reporting zero tax liabilities for 1998 through 2005 (the latest available data) and (2) characteristics of FCDCs and USCCs such as age, size, and industry. GAO analyzed data from the Internal Revenue Service's Statistics of Income samples of corporate tax returns. GAO does not make any recommendations in this report. In commenting on a draft of this report, IRS provided comments on technical issues, which we incorporated into this report where appropriate.
section_title: What GAO Found
paragraphs: FCDCs reported lower tax liabilities than USCCs by most measures shown in this report. A greater percentage of large FCDCs reported no tax liability in a given year from 1998 through 2005. For all corporations, a higher percentage of FCDCs reported no tax liabilities than USCCs through 2001 but differences after 2001 were not statistically significant. Most large FCDCs and USCCs that reported no tax liability in 2005 also reported that they had no current-year income. A smaller proportion of these corporations had losses from prior years and tax credits that eliminated any tax liability. By another measure, large FCDCs were more likely to report no tax liability over multiple years than large USCCs. In 2005, comparisons of FCDCs and USCCs based on ratios of reported tax liabilities to gross receipts or total assets showed that FCDCs reported less tax than USCCs. FCDCs and USCCs differed in age, size, and industry. FCDCs were younger than USCCs in that a greater percentage had been incorporated for 3 years or less from 1998 through 2005. In 2005, FCDCs were larger on average than USCCs in that they reported higher average gross receipts and assets than USCCs. A comparison by industry in 2005 showed that large FCDCs were relatively more concentrated in manufacturing and wholesale trade, while large USCCs were more evenly distributed across industries. GAO did not attempt to determine the extent to which these factors and others, such as transfer pricing abuse, explain differences in tax liabilities.

section_title: Letter
paragraphs: In response to your long-standing concerns about whether foreign- controlled U.S. corporations are abusing transfer prices and avoiding U.S.  income tax, we compared the tax liabilities of foreign- and U.S.-controlled  companies incorporated in the U.S. in three prior reports. We reported  that from 1989 through 2000 foreign-controlled corporations were more  likely to report zero U.S. income tax liability than U.S.-controlled  corporations with a majority of both types of corporations reporting no  liability. We said that corporations may not report U.S income taxes for a  variety of reasons including current-year operating losses, tax credits, and  transfer pricing abuses.
Transfer prices are the prices related companies, such as a parent and  subsidiary, charge on intercompany transactions.  By manipulating  transfer prices, multinational companies can shift income from higher to  lower tax jurisdictions, reducing the companies’ overall tax liability. As we  noted in our previous reports, researchers acknowledge that transfer  pricing abuses may explain some of the differences in tax liabilities of  foreign-controlled corporations compared to U.S.-controlled corporations.   However, researchers have had difficulty determining the exact extent to  which transfer pricing abuses explain the differences due to data  limitations.
Based on your request, we updated our 2004 report. Specifically, we  agreed to study (1) how the tax liability of foreign-controlled domestic  corporations (FCDC) compares to that of U.S.-controlled corporations  (USCC)—including the percentage of corporations reporting zero tax  liabilities for tax years 1998 through 2005 and (2) how corporate  characteristics such as age, size, and industry compare between FCDCs  and USCCs.
To meet these objectives, we analyzed data from the Internal Revenue  Service’s (IRS) Statistics of Income (SOI) samples of corporate tax returns  for tax years 1998 through 2005. These SOI samples were based on returns  as filed, and did not reflect IRS audit results or any net operating loss  carrybacks from future years. The data that we report are estimates based  on the SOI sample.  Sampling errors are reported in appendix II. Caution  should be used when comparing estimates because not all differences  between estimates are statistically significant. Various types of  corporations report their taxes on different forms and may differ in their  tax liabilities. Unlike our previous reports, here we report separately for  each form type.  The estimates in the body of the report are for  corporations filing Forms 1120 or 1120-A. (In app. II we provide separate  estimates for corporations filing Forms 1120-L, 1120-PC, 1120-REIT, 1120- RIC, and 1120S.) We also report separately for large corporations—those  with at least $250 million in assets or $50 million in gross receipts— because, while they account for less than 1 percent of all corporations,  they make up over 90 percent of all assets reported on corporate returns.
As agreed, we did not attempt to determine whether corporations were  abusing transfer prices. Nor did we attempt to determine the extent to  which this abuse explains any differences in the reported tax liabilities of  FCDCs and USCCs. Detailed information on our scope and methodology  appears in appendix I.
We conducted our work from November 2007 through July 2008 in  accordance with generally accepted government auditing standards. Those  standards require that we plan and perform the audit to obtain sufficient,  appropriate evidence to provide a reasonable basis for our findings and  conclusions based on our audit objectives. We believe that the evidence  obtained provides a reasonable basis for our findings and conclusions  based on our audit objectives.
subsections: section_title: Background
paragraphs: Researchers have studied the factors explaining why FCDCs report lower  tax liabilities than USCCs. Generally, the research has recognized that  nontax characteristics such as age and industry may explain some of the  differences in reported tax liabilities. The researchers have also found that  transfer pricing abuses may play a role in explaining the differences.  However, measuring the separate effects of these factors on tax liabilities  has been difficult due to data limitations.
Factors like the age and industry of corporations may affect tax liabilities  by affecting net income. For example, younger corporations may be less  likely than older corporations to have net income and, therefore, more  likely to report no tax liability than older corporations. If FCDCs tend to  be younger than USCCs, age differences may explain some of the  difference in reported tax liabilities. We noted in our 1999 report that a  study by Grubert (1997) suggested that the lower relative age of foreign- controlled corporations partially explained their lower reported  profitability. However, data are not available on all the nontax  characteristics that may affect tax liabilities.
Tax liabilities may also be reduced through transfer pricing abuse. Any  company that has a related company, such as a subsidiary with which it  transacts business, needs to establish transfer prices for those  intercompany transactions.  The transfer price should be the “arm’s length  price,” i.e., the price that would be charged if the transaction occurred  between unrelated companies. Section 482 of the Internal Revenue Code  provides IRS authority to allocate income among related companies if IRS  determines that the transfer prices used by the taxpayer were  inappropriate. How transfer prices are set affects the distribution of  profits and ultimately the taxable income of the companies. The following  is an example of abusive cross-border transfer pricing. A foreign parent  corporation with a subsidiary operating in the United States charges the  subsidiary excessive prices for goods and services rendered (for example,  $1,000 instead of the going rate of $600). This raises the subsidiary’s  expenses (by $400), lowers its profits (by $400), and effectively shifts that  income ($400) outside of the United States. At a 35-percent U.S. corporate  income tax rate, the subsidiary will pay $140 less in U.S. taxes than it  would if the $400 in profits were attributed to it.
Researchers have used direct and indirect methods to estimate the extent  to which transfer pricing abuses explain the differences in reported tax  liabilities. Direct methods analyze the transfer prices used by corporations  and compare them to arm’s length prices.  This method is difficult to apply  because price data are often unavailable and determining the price that  would be charged between unrelated parties can be difficult. An  alternative, indirect method used by researchers analyzes data about the  characteristics of corporations in order to test for a statistical relationship  between tax rates and subsidiaries’ profitability or tax liability. In some of  these studies, statistical methods are used to explain as much of the  difference in reported tax liabilities as can be explained by the nontax  characteristics and the remaining unexplained difference is identified as  the upper limit of the difference that could be explained by transfer  pricing abuse. However, how close this upper limit estimate is to the  actual effect of transfer pricing abuse depends on how many of the  important nontax characteristics have been included in the first stage of  the analysis. As noted above, data are unavailable for some important  nontax characteristics.
Low tax burdens can be measured in various ways.  Zero tax liability is  one way. However, corporations paying only small, but not zero, amounts  of tax also face low tax burdens.  Furthermore, corporations that pay no  or little tax over a number of years have a lower cumulative tax burden.  Therefore, measures based on a range of tax amounts and tax years may  give a fuller description of which types of corporations pay relatively less.  Finally, the amount of taxes paid generally corresponds with the size of  the corporation, with large corporations on average paying more than  small ones. Tax liability can be measured as the amount of tax paid as a  percentage of gross receipts or total assets in order to account for  differences in the size of corporations.
section_title: FCDCs Reported Lower Tax Liabilities Than USCCs by Most Measures
paragraphs: Our comparison of tax liabilities highlights three measures that are used  by tax experts: (1) the percentage of corporations reporting no tax  liability, (2) the number of years corporations reported no tax liability, and  (3) tax liabilities reported by corporations as a percentage of gross  receipts and assets.
subsections: section_title: A Large Percentage of Both FCDCs and USCCs Reported No Tax Liabilities
paragraphs: A greater percentage of large FCDCs reported no tax liability in a given  year from 1998 through 2005, as shown in figure 1. (See table 1 in app. II  for the detailed estimates.) From 1998 through 2001, a higher percentage  of all FCDCs reported no tax liability than all USCCs, but differences after  2001 were not statistically significant.
As figure 1 shows, the number of large FCDCs and large USCCs that  reported no tax liability peaked around 2001 and 2002. These years  correspond roughly with a period of economic recession in the United  States. However, we did not do any analysis to determine the effect of the  recession on the patterns shown if figure 1.
After 2001, the percentage of large FCDCs and USCCs reporting no tax  liability began to converge. By 2005, the difference was reduced to 3  percentage points. For corporations other than those filing tax Forms 1120  and 1120-A, the percentage of corporations that reported no tax liability  varied by tax year and tax return type. (For detailed comparisons of these  corporations, see table 2 in app. II.)
section_title: A Greater Percentage of Large FCDCs Reported No Tax Liability over Multiple Years between 1998 and 2005
paragraphs: In the 8 years from 1998 through 2005, large FCDCs in a panel data set that  we analyzed consisting of tax returns that were present in the SOI  corporate files in every year were more likely to report no tax liability over  multiple years than large USCCs in the same panel data set. As figure 2  shows, about 72 percent of FCDCs and 55 percent of USCCs reported no  tax liability for at least 1 year during the 8 years. About 57 percent of  FCDCs and 42 percent of USCCs reported no tax liability in multiple  years—2 or more years—and about 34 percent of FCDCs and 24 percent of  USCCs reported no tax liability for at least half the study period—4 or  more years. A correspondingly higher percentage of USCCs reported a tax  liability in all 8 years, 45 percent for USCCs and 28 percent for FCDCs.
Large FCDCs and USCCs reporting no tax liability in 2005 arrived at that  result in similar ways on their tax returns, as shown in figure 3. At a high  level, corporate tax returns are organized to (1) calculate gross profit as  gross receipts or sales minus the cost of goods sold; (2) calculate total  income as gross profit plus other types of income; (3) report various  deductible expenses; (4) calculate taxable income as the difference  between income and deductions; and (5) calculate the tax liability for the  taxable income. Corporations can establish the basis for a zero tax liability  at different stages in these calculations by reporting, for example, that  they have no total income or no taxable income which results in their  having no tax liability. Figure 3 shows the percentage of corporations  reporting no tax liability in 2005 by the line on their tax return where they  first reported the zero dollar amounts that resulted in no tax liability. For  example, the figure shows that 3 percent of large FCDCs and 1 percent of  large USCCs established no tax liability by reporting no gross profit on line  3 of their returns. This pattern of similar percentages for large  corporations continues throughout the tax return. For example, a similar,  small percentage of large FCDCs or USCCs, around 4 to 5 percent,  established their zero tax liability on line 11 by reporting zero total  income.
As figure 3 shows, the overwhelming majority, about 79 to 80 percent of  both large FCDCs and USCCs that reported zero tax liability in 2005,  established it on line 28 where they reported zero taxable income before  net operating losses. This means that their reported current-year  deductions more than offset the positive current-year total income  reported on line 11. The two most commonly used deductions, as a  percentage of the value of all deductions claimed, were “other  deductions” and the deduction for salaries and wages. See table 3 and  figure 8 in appendix II for detailed comparisons of tax return line items  and deductions.
On the corporate tax return, current-year taxable income is reported  before net operating losses from other years are deducted and any tax  credits are subtracted from tax liabilities. In 2005, losses from prior years  and tax credits had less impact on where on the tax return large  corporations first established no tax liability. Figure 3 shows on line 30  that a relatively small number of large corporations—about 10 percent— first established a zero tax liability by carrying forward losses from prior  years, and that an even smaller number—about 3 percent—first  established no tax liability through their use of tax credits, as reported on  line 11 schedule J in the figure.
All FCDCs and USCCs differed in some ways from large FCDCs and  USCCs in where on their tax returns they first established no tax liability,  reflecting the influence of small corporations. As figure 3 shows, a higher  percentage of all corporations established no tax liability on the gross  profit and total income lines on their returns than large corporations. All  corporations also show a greater impact of losses from prior years, with 19  to 24 percent first establishing no tax liability when they reported taxable  income on line 30 after subtracting these losses.
However, there were also similarities between all corporations and large  corporations in 2005. As with large corporations, all FCDCs and USCCs  were most likely to first establish no tax liability on line 28 of their tax  returns—over 46 percent for FCDCs and 58 percent for USCCs. In  addition, as with large corporations, tax credits had little impact with only  about 1 percent of all corporations first establishing no liability through  their use of credits.
Figure 3 also shows that all FCDCs differed from all USCCs more than the  large FCDCs differed from large USCCs. Whereas large FCDCs and USCCs  differed little in where on the return they established no tax liability, all  FCDCs were more than twice as likely to first establish no tax liability on  the gross profit and total income lines as all USCCs.
section_title: FCDCs Reported Less Tax Liability Than USCCs as a Percentage of Both Gross Receipts and Total Assets
paragraphs: Alternative comparisons of FCDCs and USCCs based on ratios of reported  tax liabilities to gross receipts or total assets also showed that FCDCs  reported less tax than USCCs. Figure 4 shows that taxes as a percentage of  gross receipts and assets were higher for USCCs than FCDCs. FCDCs  reported lower tax liabilities in 2005 as a percentage of gross receipts than  USCCs. For all FCDCs the percentage was about 1.4 percent, while for all  USCCs the percentage was about 1.7 percent. This pattern was similar for  large corporations where FCDCs had lower tax liability as a percentage of  gross receipts-about 1.3 percent compared to about 2.1 percent for large  USCCs.
Another comparison of FCDCs and USCCs based on amounts of tax  liability in addition to zero tax liability showed that differences between  FCDCs and USCCs became smaller as their reported tax liabilities  increased. The difference between the percentage of large FCDCs and  USCCs that report no tax liability was about 3 percent in 2005, and this  difference reduces to 1 percent when we include corporations reporting  tax liabilities less than $100,000 in the comparison. The difference is  eliminated entirely when we compare those that report less than $1 million  in tax liability. (For details of these comparisons, see table 4 in app. II.)
section_title: FCDCs and USCCs Differ by Age, Size, and Industry
paragraphs: Differences in age, size, industry and other nontax factors between FCDCs  and USCCs could explain some of the differences in their reported tax  liabilities. Also, companies in different industries often have different  financial characteristics which could affect relative measures of tax  liability. For instance, the relative levels of assets and receipts of  companies primarily engaged in wholesale trade differ significantly from  those primarily engaged in credit intermediation, such as commercial  banks. We did not attempt to explain the extent to which these factors or  others, such as transfer pricing abuses, might explain differences in the  reported tax liabilities of FCDCs and USCCs.
subsections: section_title: A Higher Percentage of Large FCDCs Than Large USCCs Were New
paragraphs: A higher percentage of large FCDCs than large USCCs were new  corporations (incorporated for 3 years or less) for tax years 1998 through  2005, as shown in figure 5.  The percentages of large FCDCs that were new  ranged from 9 percent to 14 percent, while for large USCCs the  percentages ranged from 7 percent to 10 percent.  For all FCDCs and  USCCs, except for 1998 through 2000, there were no years with a  statistically significant difference between the percentages of these types  of corporations that were new. (See table 5 in app. II for the detailed  estimates.)
section_title: FCDCs Reported Higher Average Gross Receipts and Assets Than USCCs
paragraphs: FCDCs tended to be larger in that in 2005 they reported higher average  assets and gross receipts than USCCs, as shown in figure 6. All FCDCs  reported an average of about $100 million in assets compared to about $9  million for all USCCs. Large FCDCs also reported higher amounts of  assets—an average of about $1.6 billion compared to about $1.1 billion for  large USCCs.
FCDCs reported more average gross receipts in 2005. All FCDCs reported  an average of about $43 million in gross receipts, while USCCs reported an  average of about $5 million. Although the magnitudes were larger for large  corporations, the pattern of gross receipts was similar. Large FCDCs  reported higher average gross receipts—about $663 million compared to  about $447 million for large USCCs.
section_title: FCDCs and USCCs Were Concentrated in Different Industries
paragraphs: In 2005, FCDCs and USCCs differed in their distribution across industries.   As figure 7 shows, all FCDCs were more concentrated in the wholesale  trade and financial services industries, while all USCCs were more  concentrated in the nonfinancial services industry. When the focus is  limited to large corporations, FCDCs were relatively more concentrated in  manufacturing and wholesale trade. Large USCCs were more evenly  distributed across the industries shown in figure 7.
Differences in cost ratios across industries are possible explanations for  why industry concentration might affect the reported tax liabilities of  FCDCs and USCCs. Cost differences could affect profits, and thus tax  liabilities. For example, the higher cost of goods sold relative to receipts  could contribute to lower taxable income relative to receipts, and  consequently lower tax liability relative to receipts. In tax year 2005, all  FCDCs were more likely to have higher cost of goods sold, purchases, and  interest as a percentage of gross receipts for most industries than were  USCCs. The results were similar for large corporations. (For details of  these comparisons of cost ratios, see table 6 in app. II.)
section_title: Agency Comments
paragraphs: We provided a draft of this report to the IRS for its comments. On July 21,  the Research, Analysis and Statistics unit provided comments via e-mail on  technical issues, which we incorporated into this report where  appropriate.
As agreed with your offices, unless you publicly announce its contents  earlier, we plan no further distribution of this report until 30 days from its  date. At that time, we will send copies of this report to the Secretary of the  Treasury, the Commissioner of Internal Revenue, and other interested  parties. This report will also be available at no charge on GAO’s Web site  at http://www.gao.gov.
If you or your staff has any questions about this report, please contact me  at (202) 512-9110 or whitej@gao.gov. Contact points for our Offices of  Congressional Relations and Public Affairs may be found on the last page  of this report. GAO staff who made contributions to this report are listed  in appendix III.
section_title: Appendix I: Objectives, Scope, and Methodology
paragraphs: The objectives of this assignment were to study (1) how the tax liability of  foreign-controlled domestic corporations (FCDC) compares to that of  U.S.-controlled corporations (USCC)—including the percentage of  corporations reporting zero tax liabilities for tax years 1998 through 2005  and (2) how corporate characteristics, such as age, size, or industry,  compare between FCDCs and USCCs. For both of our objectives, we used  data from Internal Revenue Service’s (IRS) Statistics of Income (SOI) files  on corporate tax returns for tax years 1998 through 2005. These SOI  samples were based on returns as filed, and did not reflect IRS audit  results or any net operating loss carrybacks from future years. Each tax  return is treated as a separate corporation which, in the case of  consolidated returns, may be composed of a number of subsidiary  corporations. To provide information on the number of years large  corporations did not report tax liabilities, we developed a panel data set  consisting of the tax returns of large corporations that were present in the  SOI corporate files in every year from 1998 through 2005. We did not  include corporations that changed ownership status as USCCs or FCDCs  during this period. We also did not analyze changes in the composition of  corporations that filed consolidated returns. The gross receipts and assets  of the corporations present in the panel data set account for on average  about 40 percent of gross receipts and assets of all corporations and about  50 percent of the gross receipts and assets of large corporations from 1998  through 2005. Over time, the corporations present in the panel data  account for an increasing share of corporate gross receipts and assets. For  example in 1998 and 1999 the panel data corporations accounted for about  40 percent of the gross receipts and assets of all large corporations. This  percentage increased to about 60 percent by 2005.
To compare all and large FCDCs and USCCs based on the tax liabilities  they reported on their U.S. income tax returns, we made estimates for a  variety of measures of tax liability. For the purposes of this report, an  FCDC is a U.S. corporation with 50 percent or more of its voting stock  owned by a foreign person or entity. Foreign control of a U.S. corporation  exists when a foreign investor gains control of an existing U.S. company or  creates a new company that it incorporates in the United States. Both  FCDCs and USCCs are subject to U.S. income tax laws although the tax  treatment of some income may differ. Large corporations are those with at  least $250 million of assets or at least $50 million of receipts. We also  compared differences in FCDCs and USCCs by age and industry sector.  We defined new corporations as those for which income tax returns  showed incorporation dates within 3 years of the tax year date; all others  were considered old corporations. For example, for tax year 2005, new  corporations are those with incorporation dates no earlier than 2003. We  did not attempt to determine whether corporations were abusing transfer  prices. Nor did we attempt to determine the extent to which such abuse  explains any differences in the reported tax liabilities of FCDCs and  USCCs.
The SOI corporation data we used in our comparison of tax liabilities of  FCDCs and USCCs included domestic corporations. We reported  separately for corporations that reported tax liabilities on Form 1120 (U.S.  Corporation Income Tax Return) and Form 1120-A (U.S. Corporation  Short-Form Income Tax Return). We also provided in table 2 of appendix  II information on corporations that reported no tax liabilities on Forms  1120-L (U.S. Life Insurance Company Income Tax Return), 1120-PC (U.S.  Property and Casualty Insurance Company Income Tax Return), 1120- REIT (U.S. Income Tax Return for Real Estate Investment Trusts), 1120- RIC (U.S. Income Tax Return for Regulated Investment Companies), and  1120S (U.S. Income Tax Return for an S Corporation).  Some of these  types of corporations, such as REITs and RICs, are pass-through entities  that generally do not incur corporate tax liabilities. We did not include  foreign corporations in our comparison of FCDCs and USCCs or those that  filed Form 1120-F (U.S. Income Tax Return of a Foreign Corporation).
The SOI data in this report is based on SOI’s probability sample of  corporate tax returns and thus is subject to some imprecision owing to  sampling variability. Using SOI’s sampling weights, we estimated sampling  errors for our estimates, which are reported in appendix II. Caution should  be used when comparing estimates because not all differences between  estimates are statistically significant. Differences between all FCDCs and  USCCs, and large FCDCs and USCCs, are statically significant unless  noted at the bottom of each figure or table. To ensure that the data were  comparable across years, we converted all dollar-based data to 2005  dollars.  The data included tax liabilities, total income, gross receipts,  assets, cost of goods sold, interest, and purchases reported.
SOI is a data set widely used for research purposes. SOI data are not  available to the public except in aggregate form via published tables.   These data tables are publicly available either in printed form or on the  irs.gov Web site. IRS performs a number of quality control steps to verify  the internal consistency of SOI sample data. For example, it performs  computerized tests to verify the relationships between values on the  returns selected as part of the SOI sample, and manually edits data items  to correct for problems, such as missing items. We conducted several  reliability tests to ensure that the data excerpts we used for this report  were complete and accurate. For example, we electronically tested the  data and used published data as a comparison to ensure that the data set  was complete. To ensure accuracy, we reviewed related documentation  and electronically tested for obvious errors. We concluded that the data  were sufficiently reliable for the purposes of this report.
We requested comments on a draft of this report from the Commissioner  of Internal Revenue. We conducted our review from November 2007  through July 2008 in accordance with generally accepted government  auditing standards. Those standards require that we plan and perform the  audit to obtain sufficient appropriate evidence to provide a reasonable  basis for our findings and conclusions based on our audit objectives. We  believe that the evidence obtained provides a reasonable basis for our  findings and conclusions based on our audit objectives.
section_title: Appendix II: Additional Tables
paragraphs: The tables in this statistical appendix supplement those in the letter and  provide population estimates. After each table, notes indicate the sampling  errors. We are confident the true estimates would be within these  percentage points in 95 out of every 100 samples. Finally, we conducted  tests to determine if there were significant differences between all FCDCs  and USCCs and between large FCDCs and USCCs. The comparisons that  were not statistically significant are noted in each table.
section_title: Appendix III: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Acknowledgments
paragraphs: In addition to the contact person named above, Kevin Daly, Assistant  Director; Amy Bowser; Sara Daleski; Laurie King; Donna Miller; and John  Mingus made key contributions to this report.