Publication Type
Journal Article
Version
submittedVersion
Publication Date
4-2024
Abstract
This study examines whether multinational corporations (MNCs) reclassify related-party payments to avoid the new base erosion and anti-abuse tax (BEAT). The Tax Cuts & Jobs Act of 2017 included the BEAT to combat income shifting from the U.S. to foreign entities. An exclusion in the tax law provides MNCs an incentive to reclassify related-party payments as cost of goods sold. We use a triple-difference design that leverages the BEAT filing threshold of $500 million in revenue and the parent company’s location to document increases in the unconsolidated sales of foreign subsidiaries of MNCs subject to BEAT relative foreign subsidiaries of MNCs not subject to BEAT consistent with cost reclassification. We also find this effect is strongest in MNCs with more related-party payments. Overall, our results imply that firms use the subjectivity inherent in cost classification to reclassify costs as cost of goods sold to avoid the BEAT.
Keywords
Tax planning, income shifting, cost reclassification, foreign tax, tax, TCJA, BEAT
Discipline
Accounting | Corporate Finance
Research Areas
Corporate Governance, Auditing and Risk Management
Publication
Journal of Accounting and Economics
Volume
77
Issue
2-3
First Page
1
Last Page
20
ISSN
0165-4101
Identifier
10.1016/j.jacceco.2023.101648
Publisher
Elsevier
Citation
LAPLANTE, Stacie O.; LEWELLEN, Christina M.; PYNCH, Daniel P.; and SAMUEL, Daniel M. P..
"Just BEAT it" do firms reclassify costs to avoid the base erosion and anti-abuse tax (BEAT) of the TCJA?. (2024). Journal of Accounting and Economics. 77, (2-3), 1-20.
Available at: https://ink.library.smu.edu.sg/soa_research/2023
Copyright Owner and License
Authors
Creative Commons License
This work is licensed under a Creative Commons Attribution-NonCommercial-No Derivative Works 4.0 International License.
Additional URL
https://doi.org/10.1016/j.jacceco.2023.101648