The Alternative Minimum Tax and the Behavior of Multinational Corporations

This paper examines the extent to which U.S.-based multinational corporations are affected by the alternative minimum tax. More than half of all foreign-source income received by corporations in 1990 was earned by corporations subject to the alternative minimum tax. The AMT rules potentially affect multinational corporations in a manner different from their effect on domestic corporations. The paper examines the differential incentives the AMT creates for locating investment either domestically or abroad and considers how the incentives for the repatriation of foreign-source income are affected by the AMT. Tax return data of U.S.-based multinationals are examined to see the extent to which these incentives may influence the repatriation of foreign-source income.