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This thesis examines the income-shifting behaviour of multinational corporations when they are facing international corporate income tax rate differentials. Multinational corporations may apply tax-planning strategies in order to shift their pre-tax profits from a high-tax country to a low-tax country; therefore, the same amount of money would be subject to a lower tax rate. By doing so, multinational corporations minimize their global tax liabilities without changing their total income. The first essay develops a simple general equilibrium model by which to explore the effect of tax planning on the host country in terms of social welfare and optimal taxation. We endogenize multinational corporations’ investment decisions by allowing the user cost of capital to be affected by shifting decisions. We find that if tax rates are not excessively high, then an increase in tax planning activity causes a rise in optimal corporate tax rates, and a decline in multinational investment. Thus, fears of a “race to the bottom” in corporate tax rates may be misplaced. Also, we find that the residents in high-tax countries may be better off with (some) income shifting. We prove that there is an interior optimal thin capitalization rule (a restriction on the debt-to-equity ratio) that is lower than the degree of tax planning preferred by multinational firms. The second essay empirically examines the evidence of income-shifting behaviour of Canadian multinational corporations. The results are consistent with the income-shifting hypothesis that multinationals are inclined to shift their pre-tax profits to low-tax jurisdictions. I find that having non-arm’s length transactions with related parties in tax-haven countries has a significant negative impact on the taxable income that is reported in Canada. Further, I compare the different roles between small havens and large havens and find that the effect of having transactions with small havens is significantly negative, while the effect of having transactions with large tax havens is not significant. Also, I find that if Canadian corporations control their foreign-related corporations with whom they had non-arm’s length transactions, then they are more likely to report lower taxable incomes in Canada than are those that have other types of relationships with their foreign-related corporations.

This thesis examines the income-shifting behaviour of multinational corporations when they are facing international corporate income tax rate differentials. Multinational corporations may apply tax-planning strategies in order to shift their pre-tax profits from a high-tax country to a low-tax country; therefore, the same amount of money would be subject to a lower tax rate. By doing so, multinational corporations minimize their global tax liabilities without changing their total income. The first essay develops a simple general equilibrium model by which to explore the effect of tax planning on the host country in terms of social welfare and optimal taxation. We endogenize multinational corporations’ investment decisions by allowing the user cost of capital to be affected by shifting decisions. We find that if tax rates are not excessively high, then an increase in tax planning activity causes a rise in optimal corporate tax rates, and a decline in multinational investment. Thus, fears of a “race to the bottom” in corporate tax rates may be misplaced. Also, we find that the residents in high-tax countries may be better off with (some) income shifting. We prove that there is an interior optimal thin capitalization rule (a restriction on the debt-to-equity ratio) that is lower than the degree of tax planning preferred by multinational firms. The second essay empirically examines the evidence of income-shifting behaviour of Canadian multinational corporations. The results are consistent with the income-shifting hypothesis that multinationals are inclined to shift their pre-tax profits to low-tax jurisdictions. I find that having non-arm’s length transactions with related parties in tax-haven countries has a significant negative impact on the taxable income that is reported in Canada. Further, I compare the different roles between small havens and large havens and find that the effect of having transactions with small havens is significantly negative, while the effect of having transactions with large tax havens is not significant. Also, I find that if Canadian corporations control their foreign-related corporations with whom they had non-arm’s length transactions, then they are more likely to report lower taxable incomes in Canada than are those that have other types of relationships with their foreign-related corporations.

Phase-shifting projected fringe profilometry (PSPFP) is powerful for 3D profile measurements. Test and analysis for accuracy of PSPFP is presented. A novel scheme to identify the accuracy of evaluated phases is propsed as well. This test scheme can be applied to any kind of measurements which use fringe projection techniques.

I examine an unintended consequence of countries permitting or requiring a common set of accounting standards for unconsolidated financial reporting. Specifically, I test whether adoption of IFRS facilitates income tax-motivated profit shifting by multinational entities (MNEs). MNEs often justify transfer prices to tax authorities by benchmarking intercompany profit allocations against a range of profit rates reported by economically comparable, independent firms that use similar accounting standards. A larger set of qualifying benchmark firms resulting from IFRS adoption could allow opportunistic managers to support more tax-advantaged transfer prices. I use a database of EU unconsolidated financial and ownership information to identify tax-motivated income shifting over 2001 to 2010. I estimate a statistically and economically significant 17.5 percent tax-motivated change in reported pre-tax profits following affiliate IFRS adoption, relative to no change in income shifting behavior for non-adopters. The magnitude of this effect increases in expansions to the set of potential benchmark firms upon affiliate IFRS adoption. / text

This work examines a novel method of dynamic single frame interferometry. In this dynamic approach to phase shifting measurements, steps are taken to combat performance degradation due to environmental factors such as air turbulence and vibration. We explore the system functionality and performance, and examine some of the limiting factors using this technique such as effects due to imperfect system components, irradiance variations and sensitivity of the instrument accuracy based on calculation methodology. We present the errors associated with these various aspects of the system and show the majority cause phase calculation errors less than 0.005λ P-V to the calculated wavefront. This new approach involves the placement of a micropolarizer phase-shifting array directly onto a CCD camera which allows the construction of a dynamic single frame interferometric system. Hardware and manufacturing preparations such as inspection, positioning and alignment are discussed. Experimental results of system performance are combined with mathematical simulations to provide a performance baseline. We present experimental results showing the effects of averaging on measurement data, which results in a reduction of fringe print-through errors associated with a combination of many of the system error sources.

Chronic exposure to psychostimulants such as amphetamine (AMPH) can induce long-term disruptions in cognition via actions on prefrontal cortex dopamine. Previous work has shown that two types of executive functions, set shifting and working memory (WM), are disrupted by AMPH sensitization and that these cognitive domains are impaired in schizophrenics and stimulant abusers. We assessed the effects of AMPH sensitization on behavioural flexibility using a cross-maze set shifting task and a WM task using the delayed spatial win-shift (SWSh) task in Long Evans (LE) and Sprague Dawley (SD) rats. Rats were exposed to an AMPH sensitization regimen (15 AMPH or saline injections: 1-5 mg/kg every 2nd day, increasing the dose by 1 mg every 3rd injections) following habituation on the mazes. In experiment 1, LE and SD rats were initially trained on a visual cue discrimination. During the set shift, rats were required to shift from the previously acquired visual-cue-based strategy to a response strategy (e.g.; always turn left, ignore the visual cue). For the reversal, rats were trained to reverse their turn direction. AMPH treatment did not impair learning of the initial cue discrimination in either strain. However, AMPH treated rats learned the response discrimination faster than controls during the set shift and AMPH treated LE rats were faster than controls to reach acquisition criterion during the response reversal. AMPH treatment neither impaired nor improved reversal learning in SD rats. In experiment 2, rats were tested on the SWSh task in which spatial information acquired during a training phase was used 30 minutes later during the testing phase in order to retrieve food pellets on the maze. In this task, AMPH treated rats were faster to re-attain criterion than control rats. Correlational analysis further revealed that AMPH sensitized rats that required more days to reach criterion before AMPH treatment (i.e. slow learners) tended to make more errors during re-acquisition of the memory task. Viewed collectively, these results suggest that chronic AMPH treatment can enhance behavioural flexibility and WM assessed in this manner. However, repeated AMPH exposure may have exacerbated pre-existing cognitive deficits in slow learning rats.

Chronic exposure to psychostimulants such as amphetamine (AMPH) can induce long-term disruptions in cognition via actions on prefrontal cortex dopamine. Previous work has shown that two types of executive functions, set shifting and working memory (WM), are disrupted by AMPH sensitization and that these cognitive domains are impaired in schizophrenics and stimulant abusers. We assessed the effects of AMPH sensitization on behavioural flexibility using a cross-maze set shifting task and a WM task using the delayed spatial win-shift (SWSh) task in Long Evans (LE) and Sprague Dawley (SD) rats. Rats were exposed to an AMPH sensitization regimen (15 AMPH or saline injections: 1-5 mg/kg every 2nd day, increasing the dose by 1 mg every 3rd injections) following habituation on the mazes. In experiment 1, LE and SD rats were initially trained on a visual cue discrimination. During the set shift, rats were required to shift from the previously acquired visual-cue-based strategy to a response strategy (e.g.; always turn left, ignore the visual cue). For the reversal, rats were trained to reverse their turn direction. AMPH treatment did not impair learning of the initial cue discrimination in either strain. However, AMPH treated rats learned the response discrimination faster than controls during the set shift and AMPH treated LE rats were faster than controls to reach acquisition criterion during the response reversal. AMPH treatment neither impaired nor improved reversal learning in SD rats. In experiment 2, rats were tested on the SWSh task in which spatial information acquired during a training phase was used 30 minutes later during the testing phase in order to retrieve food pellets on the maze. In this task, AMPH treated rats were faster to re-attain criterion than control rats. Correlational analysis further revealed that AMPH sensitized rats that required more days to reach criterion before AMPH treatment (i.e. slow learners) tended to make more errors during re-acquisition of the memory task. Viewed collectively, these results suggest that chronic AMPH treatment can enhance behavioural flexibility and WM assessed in this manner. However, repeated AMPH exposure may have exacerbated pre-existing cognitive deficits in slow learning rats.

Thesis (doctoral)--Universität Mainz.

Thesis (M.A.)--Carleton University, 1998. / Includes bibliographical references (leaves 157-166).