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Foreign Holding Companies and the US Taxation of Foreign Earnings: Evidence from the Tax Increase Prevention and Reconciliation Act of 2005*

Contemporary Accounting Research 2023 40(1), 729-757
ABSTRACT I analyze US multinationals' (MNCs) use of foreign holding companies in their organizational structures and the impact of holding companies on internal capital markets. The look‐thru rule in the Tax Increase Prevention and Reconciliation Act of 2005 (TIPRA) reduces the after‐tax cost of foreign intercompany financing transactions. I use TIPRA as a natural experimental setting to test whether a shift in US tax policy that reduces the cost of moving foreign capital increased firms' reliance on foreign holding company subsidiaries. I find that MNCs responded to TIPRA by creating more foreign holding companies. Furthermore, consistent with the policy objectives of TIPRA, I document that MNCs that rely on holding companies gained tax efficiencies in their post‐TIPRA foreign internal capital markets, reducing domestic taxation on foreign earnings and easing financial constraints. Overall, my results expand our understanding of foreign organizational structure decisions and their internal financing benefits. I contribute to the tax literature by documenting a response to TIPRA that sheds light on the growing complexity of foreign subsidiary ownership structures.

Tax havens and reputational costs

Journal of Accounting and Economics 2025 79(2-3), 101761 open access
In 2017, the European Commission (EC) published a list of non-cooperative tax havens. We study whether country-level tourism and foreign direct investment (FDI) change as a result of this list. Consistent with a reputational cost of the EC’s “name and shame” campaign, there is a modest reduction in EU tourism among listed countries compared to unlisted ones. This relative reduction is concentrated among tourists from countries that view cheating on taxes as less justifiable. In contrast, listed countries experience a general increase in FDI following the list, a benefit potentially offsetting the costs of reduced tourism.

Court Disclosures of Firms in Chapter 11 Bankruptcy

Journal of Accounting Research 2025 63(1), 57-112 open access
ABSTRACT Stakeholders in the Chapter 11 reorganization process face significant information uncertainty about the post‐emergence prospects of the firm. The U.S. Bankruptcy Code requires a debtor to provide a disclosure statement containing “adequate information” about its financial status and a proposed reorganization plan but stops short of rigidly defining the adequacy standard. We document the heterogeneity in disclosure statement information across 16 distinct attributes and examine the variation in disclosures along several dimensions that reflect agency costs and coordination problems. We observe that Chapter 11 disclosure correlates more with claimant‐ and case‐specific characteristics than pre‐bankruptcy debtor characteristics. Our results illustrate the importance of institutional features in specific disclosure settings such as bankruptcy court filings. The research questions and methods of this study were registered via the Journal of Accounting Research ’s registration‐based editorial process.