The financing and taxation of U.S. direct investment abroad

The author examines the financing of U.S. direct investment abroad. Using a theoretical model, he first examines how home country investors can use debt finance to reduce their host country tax liability and to reduce the capital investment distortion attributable to foreign taxes. Empirically, U.S. affiliates are shown to use leverage in high tax environments and in situations where the affiliates face high foreign wage bills relative to assets. This confirms the notion that leverage can be used to ward off host country tax and wage pressures on the firm. The author examines what characteristics of foreign direct investment determine the average host country tax rate paid. Generally, the taxation of foreign direct investment is positively related to the size of the wage bill. Host countries appear to charge lower taxes in cases where U.S. direct investor abroad pay high wage bills to labor within the host country. Certain trends emerge from the data: there is a relative shift of U.S. direct investment abroad toward the industrial countries; debt finance of direct investment is becoming more important in industrial countries and less important in developing countries; and the tax benefits that industrialand developing countries get from U.S. affiliates, as measured by average income and payroll taxes, are waning. The downward trend in tax rates suggests an increased international competition to attract foreign direct investment. The reduction in average tax rates on U.S. investment abroad and the relative shift toward investment in industrial countries suggests a tougher climate ahead for developing countries that wish to attract foreign direct investment. One strategy for attracting foreign investment would be to deepen the domestic financial market so a multinational can attract additional lending capital in the host country itself. Another approach is local equity participation in foreign direct investment to lessen the incentives for host countries to tax foreign investments highly.Environmental Economics&Policies,Public Sector Economics&Finance,Banks&Banking Reform,International Terrorism&Counterterrorism,Economic Theory&Research

How factors in creditor countries affect secondary market prices for developing country debt

Bank loans to many developing countries trade at a discount on the secondary market. These discounts are typically assumed to reflect only the repayment prospects of the borrower country. But the authors demonstrate that factors in the creditor countries have a major impact on secondary market prices. Their empirical investigation suggests a systematic relationship between secondary market prices and the size distribution of banks'portfolios. There is a strong negative correlation between discounts in the secondary market and U.S. banks'heavy exposure to developing country debt. It is estimated that every US$4 billion increase in a large bank's exposure to a country reduces the discount 10 to 15 cents on the dollar. The authors find that discounts and total bank capital are positively correlated over time : a US$8 billion increase in the capital of the largest U.S. banks increases discounts by nearly 25 cents on the dollar. They explain their results with a simulation model of a representative bank with minimum capital requirements, flat-rate deposit insurance, and limited liability. The bank's portfolio adjustment decision involves trading risky foreign loans in the secondary market or making short-term domestic loans. The model yields a negative relationship between the banks'exposure to developing countries and discounts in the secondary market.Banks&Banking Reform,Financial Intermediation,Economic Theory&Research,Environmental Economics&Policies,Financial Crisis Management&Restructuring

Bank Exposure, Capital and Secondary Market Discounts on the Developing Country Debt

Previous empirical studies of secondary market discounts for developing countries have ignored important creditor country factors. The empirical evidence in this paper indicates that, after controlling for repayment indicators of borrower countries, bank exposure and capital are important determinants of secondary market discounts: an increase in the exposure of large banks to a particular country leads to a decrease in the secondary market discounts on the debt of that country, while an increase in the capital of large banks leads to an increase in secondary market discounts. Among the repayment indicators of developing countries, only debt ratios are found to be significant determinants of the discounts. We suggest that the impacts of exposure and capital can be explained by the presence of deposit insurance. The evidence presented on the stock market pricing of lender banks supports this view.

U.S. Commercial Banks and the Developing-Country Debt Crisis

macroeconomics,commercial banks, developing countries, debt

The Taxation of Interest in Europe: A Minimum Withholding Tax?

This paper provides an analysis of the proposal for introducing a minimum withholding tax on interest in the EU. We present a model with three countries: a typical EU country, an 'inside' tax haven, and an 'outside' tax haven. In the initial non-cooperative solution, the former two countries impose withholding taxes on interest. We investigate what happens to welfare in these countries, if the 'inside' tax haven is forced to raise its withholding tax. From the model we proceed to a broader evaluation of the minimum withholding tax proposal.

Are banks too big to fail or too big to save ? International evidence from equity prices and CDS spreads

Deteriorating public finances around the world raise doubts about countries'abilities to bail out their largest banks. For an international sample of banks, this paper investigates the impact of government indebtedness and deficits on bank stock prices and credit default swap spreads. Overall, bank stock prices reflect a negative capitalization of government debt and they respond negatively to deficits. The authors present evidence that in 2008 systemically large banks saw a reduction in their market valuation in countries running large fiscal deficits. Furthermore, the change in bank credit default swap spreads in 2008 relative to 2007 reflects countries'deterioration of public deficits. The results of the analysis suggest that some systemically important banks can increase their value by downsizing or splitting up, as they have become too big to save, potentially reversing the trend to ever larger banks. The paper also documents that a smaller proportion of banks are systemically important -- relative to gross domestic product -- in 2008 than in the two previous years, which could reflect private incentives to downsize.Banks&Banking Reform,Debt Markets,Access to Finance,Bankruptcy and Resolution of Financial Distress,Economic Theory&Research

Official credits to developing countries : implicit transfers to the banks

This paper investigates the impact on the wealth of bank share holders on the transfer of official resources to the debtor countries. The main aim was to derive actual estimates of increases in shareholder wealth following important news concerning future transfers from the multilaterals to the debtor nations. The main result, is that stock market expects virtually all additional resources provided to debtor countries to be used for debt service to commercial banks. While the estimated magnitude of these effects are informative, the emphasis should be on the direction of these effects as they are robust to overestimation problems. Clearly, official resources provided to debtor countries do devolve to creditor banks. However, the debtor countries should at least gain in so far as the reduction of a debt overhang eliminates investment distortions. The results stem from the fact that some of the monies provided by the multilaterals are specifically earmarked for debt service or are in the form of general balance-of-payments support that the developing countries can use for private debt service. Official creditor resources that are specially provided to finance development projects are less likely to be allocated to bank debt service.Financial Crisis Management&Restructuring,Municipal Financial Management,Economic Theory&Research,Banks&Banking Reform,Financial Intermediation