Tax Administration:

Foreign- and U.S.-Controlled Corporations That Did Not Pay U.S. Income Taxes, 1989-95

GGD-99-39: Published: Mar 23, 1999. Publicly Released: Apr 14, 1999.


James R. White
(202) 512-5594


Office of Public Affairs
(202) 512-4800

Pursuant to a congressional request, GAO provided an update to its report on the nonpayment of U.S. income taxes by foreign-controlled corporations (FCC) and U.S.-controlled corporations (USCC), focusing on comparisons of: (1) the percentages of FCCs and USCCs that filed income tax returns showing no tax liabilities for 1989 through 1995, the latest years for which data were available; and (2) selected characteristics, including age, industrial sector, and certain cost ratios, of large corporations--those with assets of $250 million or more or gross receipts of $50 million or more.

GAO noted that: (1) in each year between 1989 and 1995, a majority of corporations, both foreign- and U.S.-controlled, paid no U.S. income tax; (2) among large corporations, the percentage of FCCs that paid no tax exceeded that for USCCs from 1989 through 1993; (3) in 1994, the difference between the two groups was not statistically significant, and in 1995, the percentage of large FCCs that paid no U.S. income tax was slightly less than that of large USCCs; (4) differences in the characteristics of large FCCs and USCCs may account for part of the differences in the amount of taxes paid by the two groups; (5) one difference was the percentage of new corporations--3 years old or less--in each group; (6) the Internal Revenue Service data GAO reviewed indicate that newer corporations were less likely than older corporations to pay taxes; (7) from 1989 to 1993, a greater percentage of large FCCs than large USCCs were new, but from 1994 to 1995, a greater percentage of large USCCs than large FCCs were new; (8) another significant difference between large FCCs and large USCCs was in their distribution across industrial sectors; (9) in 1995, in comparison to large USCCs, large FCCs were more heavily concentrated in the manufacturing and wholesale trade sectors and less concentrated in the financial services sector; (10) aggregate ratios of costs to receipts for all large corporations differed significantly across industrial sectors; (11) the difference in cost ratios across industries, combined with the fact that large FCCs and USCCs were concentrated in different industries, could account for some of the difference in the amount of taxes that large FCCs paid per dollar of receipts and that large USCCs paid; and (12) the ratio of taxable income per dollar of receipts should be inversely related to the ratio of costs per dollar of receipts.

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