Raymond J. Mataloni, Jr.

Strategic behavior by U.S. multinational enterprises (MNEs) to shift profits between countries to reduce their worldwide tax burden has been well studied. Much of the existing research has focused on the use of debt payments and intrafirm intellectual property licensing agreements to explain why and how MNEs shift income across national borders. Although these tax strategies may become less important following the U.S. Tax Reform Act of 2017, there is evidence they have had a large impact on measures of economic activity in recent years. This paper explores how U.S. MNEs have used cost sharing agreements between U.S. parent companies and their foreign affiliates to shift ownership of intangible assets to lower tax jurisdictions at less-than-arm’s-length prices. These transactions reduce measured U.S. GDP and raise measured GDP in the host countries of foreign affiliates. Our empirical results are consistent with this behavior. They provide a microeconomic view of how strategic movement of intellectual property affects key measures in the national and international economic accounts, such as GDP and the trade balance.

Despite an extensive literature on the determinants of the foreign location choices by multinational companies, researchers have only recently begun to systematically examine how these companies form their location consideration sets. When considering new foreign locations, do firms evaluate the attributes of the alternatives at the national level, the sub-national regional level, at some other level of geographical aggregation, or using some combination of these? This paper employs discrete choice models to examine how U.S. multinational companies form their location consideration sets and to identify some of the relevant location attributes. The results indicate that U.S. firms tend to employ a sequential, or hierarchical, decision-making process in which a host country is first chosen based on one set of attributes and then a region within that country is chosen based on another set of attributes. The relevant location attributes include industrial agglomeration and labor market conditions.