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Report to Congressional Requesters:

February 2004:

TAX ADMINISTRATION:

Comparison of the Reported Tax Liabilities of Foreign-and U.S.-
Controlled Corporations, 1996-2000:

[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-04-358]: 

GAO Highlights:

Highlights of GAO-04-358, a report to congressional requesters 

Why GAO Did This Study:

In prior reports, GAO found differences in the percentages of foreign-
controlled corporations (FCC) and U.S.-controlled corporations (USCC) 
reporting no tax liability. Based on concerns that FCCs could be 
avoiding taxes by improperly shifting income to lower tax countries, 
GAO was asked to compare, for the years 1996 through 2000, (1) FCCs and 
USCCs, based on the tax liabilities they reported on their U.S. income 
tax returns—including the percentages reporting zero liabilities—and 
(2) the differences in FCCs and USCCs in terms of age and industry 
concentration and the extent to which these differences might explain 
tax reporting patterns. The report provides information separately for 
large corporations—those with at least $250 million in assets or $50 
million in gross receipts—because, while they account for only 1 
percent of all corporations, they own over 93 percent of all assets 
reported on corporate returns.

What GAO Found:

Comparisons of the tax liabilities of FCCs and USCCs from 1996 to 2000 
varied depending on the measure. 

* A majority of all corporations reported no tax liabilities during 
these years, with a higher percentage of FCCs doing so than USCCs. 
However, the results were reversed for large corporations. 
* A higher percentage of USCCs than FCCs reported tax liabilities of 
less than 5 percent of their total income, with similar results for 
large corporations.
* FCCs reported a lower amount of tax liability per $1,000 in gross 
receipts than USCCs. The relationship was similar for large 
corporations.

FCCs and USCCs differ with respect to their age and industry 
concentrations. A greater percentage of FCCs than USCCs were new—
incorporated for less than 3 years. FCCs were more concentrated in 
wholesale trade and financial services while USCC were more 
concentrated in nonfinancial services. Large FCCs and USCCs also 
differed in their age and industry concentrations. Age and industry 
concentration have been cited as possible explanations for the 
differences in tax liabilities reported by FCCs and USCCs. However, 
after controlling for age and industry concentration using a simple 
statistical model, the differences in taxes reported by FCCs and USCCs 
were not fully explained by these factors.

www.gao.gov/cgi-bin/getrpt?GAO-04-358.

To view the full product, including the scope and methodology, click on 
the link above. For more information, contact Jim White at (202) 
512-9110 or whitej@gao.gov.

[End of section]

Contents:

Letter: 

Results in Brief: 

Background: 

Scope and Methodology: 

Comparisons of the Tax Liabilities of FCCs and USCCs Depend on the 
Measure Used: 

Age and Industry Concentration May Explain Some Differences in FCCs and 
USCCs Reporting No or Little Tax Liability: 

Agency Comments: 

Appendixes:

Appendix I: Additional Tables: 

Appendix II: Statistical Analysis Using Logistic Regression: 

Appendix III: GAO Contacts and Staff Acknowledgments: 

GAO Contacts: 

Acknowledgments: 

Tables: 

Table 1: Estimated Percentage of Returns and Tax Liability Per $1,000 in 
Gross Receipts for All and Large FCCs and USCCs, Tax Year 2000: 

Table 2: Estimated Percentage Distribution of FCCs and USCCs by Major 
Industry, Tax Year 2000: 

Table 3: Estimated Percentage Distribution of Large FCCs and USCCs by 
Major Industry, Tax Year 2000: 

Table 4: Estimated Number and Percentage of Returns for FCCs and USCCs 
Reporting No Tax Liability: 

Table 5: Estimated Percentage Distribution of FCCs and USCCs by Tax 
Liability as Share of Total Income, Tax Years 1996-2000: 

Table 6: Estimated Percentage Distribution of Large FCCs and USCCs by 
Tax Liability as Share of Total Income, Tax Years 1996-2000: 

Table 7: Estimated Average Tax Liability Per $1,000 of Gross Receipts 
for All and Large FCCs and USCCs, Tax Years 1996-2000: 

Table 8: Profile of FCCs and USCCs by Estimated Amount of Income Tax 
Liability, Tax Year 2000: 

Table 9: Profile of Large FCCs and USCCs by Estimated Amount of Income 
Tax Liability, Tax Year 2000: 

Table 10: Estimated FCCs and USCCs Reporting No Tax Liability That Are 
Large and Small as a Percentage of All FCCs and USCCs, Tax Years 1996-
2000: 

Table 11: Estimated Percentages of FCCs and USCCs That Were New, Tax 
Years 1996-2000: 

Table 12: Estimated Percentages of Large FCCs and USCCs That Were New, 
Tax Years 1996-2000: 

Table 13: Estimated Percentage Distribution of FCCs and USCCs by Major 
Industry, Tax Years 1996-2000: 

Table 14: Estimated Percentage Distribution of FCCs and USCCs Reporting 
No Tax Liability by Major Industry, Tax Years 1996-2000: 

Table 15: Estimated Percentage Distribution of Large FCCs and USCCs by 
Major Industry, Tax Years 1996-2000: 

Table 16: Estimated Percentage Distribution of Large FCCs and USCCs 
Reporting No Tax Liability by Major Industry, Tax Years 1996-2000: 

Table 17: Estimated Percentage of FCCs and USCCs That Reported No Tax 
Liability in Each Industry, Tax Years 1996-2000: 

Table 18: Estimated Percentage of Large FCCs and USCCs That Reported No 
Tax Liability in Each Industry, Tax Years 1996-2000: 

Table 19: Estimated Cost Ratios for All FCCs and USCCs by Major 
Industry, Tax Year 2000: 

Table 20: Estimated Cost Ratios for Large FCCs and USCCs by Major 
Industry, Tax Year 2000: 

Table 21: Estimated Percentages and Odds on Reporting No Tax Liability 
and Tax Liability of Less Than 5 Percent of Total Income, between All 
FCCs and USCCs and Odds Ratios Indicating the Difference between FCCs 
and USCCs, before and after Controlling for Age and Industry Sector, 
Tax Years 1996-2000: 

Table 22: Estimated Percentages and Odds on Reporting No Tax Liability 
and Tax Liability of Less Than 5 Percent of Total Income, between Large 
FCCs and USCCs and Odds Ratios Indicating the Difference between Large 
FCCs and USCCs, before and after Controlling for Age and Industry 
Sector, Tax Years 1996-2000: 

Figures: 

Figure 1: Estimated Percentages of FCCs and USCCs That Reported No Tax 
Liability, Tax Years 1996-2000: 

Figure 2: Estimated Percentages of FCCs and USCCs Reporting Less Than 5 
Percent in Tax Liability Relative to Total Income, Tax Years 1996-2000: 

Figure 3: Estimated Percentages of FCCs and USCCs That Were New, Tax 
Years 1996-2000: 

Figure 4: Estimated Percentages of Large FCCs and USCCs That Were New, 
Tax Years 1996-2000: 

Letter February 27, 2004:

The Honorable Byron Dorgan: 
Ranking Minority Member: 
Subcommittee on Competition, Foreign Commerce and Infrastructure:  
Committee on Commerce, Science and Transportation: 
United States Senate:

The Honorable Carl Levin: 
Ranking Minority Member: 
Permanent Subcommittee on Investigations:  
Committee on Governmental Affairs:  
United States Senate:

In response to congressional requests, we have previously reported on 
the tax liabilities reported by foreign-and U.S.-controlled 
corporations. Most recently, in March 1999, we reported on differences 
in the percentages of foreign-controlled corporations (FCC) and U.S.-
controlled corporations (USCC) reporting no income tax liability. We 
found that for each year from 1989 through 1995, FCCs were more likely 
to report zero tax liability than USCCs, though for large corporations 
the distinction was not as clear-cut. We said that transfer pricing 
abuses[Footnote 1] and other factors such as age and industry 
concentration of corporations were possible explanations for the 
differences in the percentages of FCCs and USCCs reporting zero tax 
liabilities.[Footnote 2]

You asked us to update our 1999 report. For the years 1996 through 2000 
(the last year with data available), we agreed to compare (1) FCCs and 
USCCs based on the tax liabilities they reported on their U.S. income 
tax returns--including the percentages reporting zero liabilities--and 
(2) the differences in FCCs and USCCs in terms of age and industry 
concentration and the extent to which these differences might explain 
tax reporting patterns.

To meet these objectives, we analyzed data from the Internal Revenue 
Service's (IRS) Statistics of Income (SOI) samples of corporate tax 
returns for tax years 1996 through 2000. These samples were based on 
returns as filed and did not reflect IRS audit results or any net 
operating loss carrybacks from future years. The statistics in the 
report are estimates based on the SOI sample. Sampling errors are 
reported in appendix I. Caution should be used when comparing estimates 
because not all differences between estimates are statistically 
significant. We also used statistical modeling to estimate the 
likelihood of FCCs and USCCs reporting little or no U.S. income tax 
liability, holding age and industry sector constant. We report 
separately for large corporations--those with at least $250 million in 
assets or $50 million in gross receipts--because, while they account 
for only 1 percent of all corporations, they make up over 93 percent of 
all assets reported on corporate returns. We did not attempt to 
determine whether corporations were abusing transfer prices.

Results in Brief:

Comparisons of the tax liabilities of FCCs and USCCs from 1996 through 
2000 varied depending on the measure.

* A majority of all corporations reported no liabilities during these 
years with a higher percentage of FCCs doing so than USCCs, an 
estimated average of 71 percent and 61 percent, respectively. However, 
the results were reversed for large corporations with a greater 
percentage of large USCCs reporting no tax liability.

* A greater percentage of USCCs than FCCs reported tax liabilities of 
less than 5 percent of their total income, an estimated 94 percent and 
89 percent, respectively, in 2000. The results were similar for large 
corporations. In 2000, an estimated 82 percent of large USCCs and 76 
percent of large FCCs reported taxes of less than 5 percent of their 
total income.

* However, FCCs reported less tax liability per gross receipts than 
USCCs; in 2000, an estimated average of $11.88 in tax liability per 
$1,000 in gross receipts compared with an estimated $14.75 reported by 
USCCs. A similar relationship held for large corporations.

Differences in age and industry concentration have been cited as 
possible explanations for differences in the tax liabilities reported 
between FCCs and USCCs. Compared with USCCs, a greater percentage of 
FCCs were new--incorporated for less than 3 years--for every year from 
1996 through 2000. New firms may have greater expenses relative to 
receipts and, therefore, lower taxable income. A comparison of industry 
concentrations showed that FCCs were concentrated in different 
industries compared with USCCs. Large FCCs and USCCs also exhibited 
differences in age and industry concentration. Our analysis using a 
simple regression model showed that age and industry do not fully 
explain the differences between FCCs and USCCs in reporting no tax 
liabilities or tax liabilities less than 5 percent of total income.

Background:

In prior reports, we found that a higher percentage of FCCs than USCCs 
reported no U.S. income tax from 1987 through 1995.[Footnote 3] Some of 
the reasons why FCCs and USCCs may not report U.S. income tax include 
current-year operating losses, losses carried forward from preceding 
tax years, sufficient tax credits available to offset tax liabilities, 
and improper pricing of intercompany transactions. Any company that has 
a related company with which it transacts business needs to establish 
transfer prices for those intercompany transactions. The pricing of 
intercompany transactions affects the distribution of profits and 
ultimately the taxable income of the companies. Transfer pricing abuse 
occurs when income and expenses are improperly allocated among 
interrelated companies for the purpose of reducing taxable income in a 
high-tax jurisdiction.

As we noted in our two earlier reports, researchers have attempted to 
explain why FCCs report lower tax liabilities than USCCs. Generally, 
the research has recognized that some of the nontax characteristics of 
firms, such as age and industry classification, may explain some of the 
differences in reported tax liabilities. At the same time, researchers 
have acknowledged that transfer pricing abuses may explain some of the 
differences, but they have not been able to determine the extent to 
which transfer pricing abuses explain the differences in the taxes 
reported by FCCs and USCCs.

For the purposes of this report, an FCC is either a foreign corporation 
or a U.S. corporation with 50 percent or more of its voting stock owned 
by a foreign person or entity. Foreign ownership or control of a U.S. 
corporation exists when a foreign investor gains control of an existing 
U.S. company or creates a new company and incorporates it in the United 
States. Both FCCs and USCCs are subject to U.S. income tax laws 
although the tax treatment of some income may differ.

Scope and Methodology:

For both of our objectives, we used data from IRS's SOI files on 
corporate tax returns for 1996 through 2000 to make estimates for the 
population of FCCs and USCCs. The SOI corporation data we used for our 
analyses included all types of corporations except for subchapter S 
corporations,[Footnote 4] which are treated similarly to partnerships 
for federal income tax purposes. The SOI data in this report are based 
on SOI's probability sample of corporate tax returns and thus are 
subject to some imprecision owing to sampling variability. Using SOI's 
sampling weights, we estimated sampling errors for our estimates, which 
are reported in appendix I. Caution should be used when comparing 
estimates because not all differences between estimates are 
statistically significant. Differences between all FCCs and USCCs, 
between FCCs and USCCs reporting no tax liability, between large FCCs 
and USCCs, and between large FCCs and USCCs reporting no tax liability 
are statistically significant unless noted at the bottom of each figure 
or table. To ensure that the data were comparable across years, we 
converted all dollar-based data to 2000 dollars. These data included 
tax liabilities, total income, gross receipts, assets, cost of goods 
sold, interest, and purchases reported.

SOI is a data set widely used for research purposes. IRS performs a 
number quality control steps to verify the internal consistency of SOI 
sample data. For example, it performs computerized tests to verify the 
relationships between values on the returns selected as part of the SOI 
sample, and manually edits data items to correct for problems, such as 
missing items. We conducted several reliability tests to ensure that 
the data excerpts we used for this report were complete and accurate. 
For example, we electronically tested the data and used published data 
as a comparison to ensure that the data set was complete. To ensure 
accuracy, we reviewed related documentation and electronically tested 
for obvious errors. We concluded that the data were sufficiently 
reliable for the purposes of this report.

To compare FCCs and USCCs based on the tax liabilities they reported on 
their U.S. income tax returns, we made estimates for a variety of 
measures of tax liability.

We also used SOI data to analyze differences in FCCs and USCCs by age 
and industry sector, the same factors we used in the 1999 report. We 
defined new corporations as those for which income tax returns showed 
incorporation dates within 3 years of the tax year date; all others 
were considered old corporations. For example, for tax year 2000, new 
corporations are those with incorporation dates no earlier than 1998. 
Next, we used a simple logistic regression model to estimate the 
likelihood of FCCs and USCCs reporting no tax liability or less than 5 
percent in tax liability relative to total income, after controlling 
for age and industry sector. We also used the model to compare large 
FCCs and USCCs--corporations with at least $250 million in assets or 
$50 million in gross receipts. The simple model allowed us to compare 
FCCs and USCCs while holding age and industry constant. Our simple 
model did not control for other possible influences. For a further 
explanation of the regression model, see appendix II.

We requested comments on a draft of this report from the Commissioner 
of Internal Revenue. We conducted our review from July 2003 through 
February 2004 in accordance with generally accepted government auditing 
standards.

Comparisons of the Tax Liabilities of FCCs and USCCs Depend on the 
Measure Used:

Comparisons of the tax liabilities of FCCs and USCCs vary and depend 
upon the measure used. Our comparisons highlight three measures: (1) 
the percentage of corporations reporting no tax liability, (2) the 
percentage of corporations reporting tax liabilities less than 5 
percent of their total income, and (3) reported tax liabilities per 
$1,000 of gross receipts. The first and third measures were highlighted 
in our 1999 report. We added the second measure to provide more 
information about corporations reporting little or no tax liability.

A Higher Percentage of FCCs Than USCCs Reported No Tax Liabilities:

Similar to our 1999 report, a majority of corporations, both FCCs and 
USCCs, reported no tax liability from 1996 through 2000. During this 
time, there was a higher percentage of FCCs compared with USCCs that 
reported no tax liability. Overall, an estimated average of 71 percent 
of FCCs and 61 percent of USCCs reported no tax liability during this 
period. (See fig. 1 and table 4 in app. I.):

However, among large corporations, which owned a majority of assets 
reported by all corporations, the results were reversed. A higher 
percentage of large USCCs compared to large FCCs reported no tax 
liability during the same period. (See fig. 1 and table 6 in app. I.):

Figure 1: Estimated Percentages of FCCs and USCCs That Reported No Tax 
Liability, Tax Years 1996-2000:

[See PDF for image]

[End of figure]

A Larger Percentage of USCCs Than FCCs Reported Tax Liabilities of Less 
Than 5 Percent of Total Income:

For each year from 1996 through 2000, a higher percentage of USCCs than 
FCCs reported tax liability of less than 5 percent of their total 
income.[Footnote 5] For example, in 2000, an estimated 94 percent of 
USCCs and 89 percent of FCCs reported less than 5 percent in tax 
liability. The relationship was the same for large corporations. In 
2000, an estimated 82 percent of large USCCs and 76 percent of large 
FCCs reported tax liability of less than 5 percent of their income. 
(See fig. 2 and tables 5 and 6 in app. I.):

Figure 2: Estimated Percentages of FCCs and USCCs Reporting Less Than 5 
Percent in Tax Liability Relative to Total Income, Tax Years 1996-2000:

[See PDF for image]

Note: Differences between large FCCs and large USCCs are not 
statistically significant in 1996.

[End of figure]

FCCs Reported Less Tax Liability Relative to Gross Receipts Than USCCs:

FCCs reported less tax liability as a percentage of gross 
receipts[Footnote 6] than USCCs. Overall, in 2000, FCCs reported an 
estimated $11.88 in tax liability per $1,000 in gross receipts compared 
with an estimated $14.75 reported by USCCs. (See table 1.) Among large 
corporations, FCCs also reported less tax liability relative to gross 
receipts than USCCs. These data were consistent across all years in the 
reporting period for both all corporations and for large corporations. 
(See table 7 in app. I.) Another way of comparing tax liabilities is by 
the percentage of corporations reporting a tax liability below an 
arbitrary amount. For example, in 2000, an estimated 92 percent of all 
FCCs and an estimated 98 percent of all USCCs reported less than 
$100,000 in tax liability. The percentages were not as high for large 
corporations: an estimated 46 percent of large FCCs and 53 percent of 
large USCCs reported less than $100,000 in tax liability. (See tables 8 
and 9 in app. I.):

Table 1: Estimated Percentage of Returns and Tax Liability Per $1,000 
in Gross Receipts for All and Large FCCs and USCCs, Tax Year 2000:

Distribution by income tax liability; FCCs: No tax liability; 
Percentage of returns (all): 73.3; 
Percentage of returns (large): 37.5; 
Tax liability/$1,000 receipts (all): [A]; 
Tax liability/$1,000 receipts (large): [A].

Distribution by income tax liability; FCCs: $1 or more but less than 
$100,000; 
Percentage of returns (all): 18.2; 
Percentage of returns (large): 8.7; 
Tax liability/$1,000 receipts (all): $2.70; 
Tax liability/$1,000 receipts (large): $0.29[B].

Distribution by income tax liability; FCCs: $100,000 or more but less 
than $1 million; 
Percentage of returns (all): 6.1; 
Percentage of returns (large): 18.9; 
Tax liability/$1,000 receipts (all): 7.18; 
Tax liability/$1,000 receipts (large): 1.75.

Distribution by income tax liability; FCCs: $1 million or more; 
Percentage of returns (all): 2.4; 
Percentage of returns (large): 34.9; 
Tax liability/$1,000 receipts (all): 20.25; 
Tax liability/$1,000 receipts (large): 19.39.

Distribution by income tax liability; FCCs: Total; 
Percentage of returns (all): 100.0; 
Percentage of returns (large): 100.0; 
Tax liability/$1,000 receipts (all): $11.88; 
Tax liability/$1,000 receipts (large): $11.52.

Distribution by income tax liability; USCCs: No tax liability; 
Percentage of returns (all): 63.0; 
Percentage of returns (large): 45.3; 
Tax liability/$1,000 receipts (all): [A]; 
Tax liability/$1,000 receipts (large): [A].

Distribution by income tax liability; USCCs: $1 or more but less than 
$100,000; 
Percentage of returns (all): 35.0; 
Percentage of returns (large): 8.0; 
Tax liability/$1,000 receipts (all): $4.11; 
Tax liability/$1,000 receipts (large): $0.29[B].

Distribution by income tax liability; USCCs: $100,000 or more but less 
than $1 million; 
Percentage of returns (all): 1.6; 
Percentage of returns (large): 17.1; 
Tax liability/$1,000 receipts (all): 12.16; 
Tax liability/$1,000 receipts (large): 2.95.

Distribution by income tax liability; USCCs: $1 million or more; 
Percentage of returns (all): 0.3; 
Percentage of returns (large): 29.5; 
Tax liability/$1,000 receipts (all): 21.96; 
Tax liability/$1,000 receipts (large): 21.50.

Distribution by income tax liability; USCCs: Total; 
Percentage of returns (all): 99.9; 
Percentage of returns (large): 99.9; 
Tax liability/$1,000 receipts (all): $14.75; 
Tax liability/$1,000 receipts (large): $16.65. 

Source: GAO analysis of IRS data.

Note: Columns may not sum to 100 because of rounding.

[A] Not applicable.

[B] Differences between large FCCs and large USCCs are not 
statistically significant.

[End of table]

Age and Industry Concentration May Explain Some Differences in FCCs and 
USCCs Reporting No or Little Tax Liability:

FCCs and USCCs differ in terms of age and industry concentration. These 
factors could possibly explain some of the differences in the tax 
liabilities reported by FCCs and USCCs. However, when we used a simple 
statistical model to control for age and industry sector, differences 
remained in the percentages of FCCs and USCCs reporting no or little 
tax liability.

A Larger Percentage of FCCs Were New Compared to USCCs:

For every year from 1996 through 2000, a greater estimated percentage 
of FCCs compared to USCCs were new (incorporated for 3 years or less). 
New firms may have greater expenses relative to receipts and, 
therefore, lower taxable income. Among corporations reporting no tax 
liability, the differences in age between FCCs and USCCs were not 
always statistically significant. (See fig. 3 and table 11 in app. I.):

Figure 3: Estimated Percentages of FCCs and USCCs That Were New, Tax 
Years 1996-2000:

[See PDF for image]

Notes: "New" includes FCCs and USCCs incorporated within 3 years. 
Differences between FCCs and USCCs that reported no tax liability were 
not statistically significant in 1997, 1998, 1999, and 2000.

[End of figure]

When comparing large corporations, the percentage that was new was also 
higher for large FCCs than USCCs. Among large corporations reporting no 
tax liability, a larger percentage of FCCs were new compared with 
USCCs. However, not all the differences were statistically significant. 
(See fig. 4 and table 12 in app. I.):

Figure 4: Estimated Percentages of Large FCCs and USCCs That Were New, 
Tax Years 1996-2000:

[See PDF for image]

Notes: Differences between all large FCCs and all large USCCs are not 
statistically significant in 1996. Differences between large FCCs and 
large USCCs reporting no tax liability are not statistically 
significant in 1996 and 1997.

[End of figure]

FCCs and USCCs Were Concentrated in Different Industries:

FCCs and USCCs differed in their concentration among industries. In 
2000, FCCs were more concentrated in the wholesale trade and financial 
services industries while USCCs were more concentrated in the 
nonfinancial services industry. Industry concentration did not change 
much when looking at only corporations reporting no tax liability. (See 
table 2.):

Table 2: Estimated Percentage Distribution of FCCs and USCCs by Major 
Industry, Tax Year 2000:

Industry: Manufacturing; 
FCCs, all: 10.6; 
FCCs, no tax: 7.5[A]; 
USCCs, all: 6.7; 
USCCs, no tax: 6.6[A].

Industry: Wholesale trade; 
FCCs, all: 22.2; 
FCCs, no tax: 20.5; 
USCCs, all: 8.2; 
USCCs, no tax: 7.4.

Industry: Financial services; 
FCCs, all: 31.8; 
FCCs, no tax: 34.6; 
USCCs, all: 15.2; 
USCCs, no tax: 14.3.

Industry: Nonfinancial services; 
FCCs, all: 18.5; 
FCCs, no tax: 18.5; 
USCCs, all: 37.5; 
USCCs, no tax: 40.5.

Industry: Retail; 
FCCs, all: 4.8; 
FCCs, no tax: 4.9; 
USCCs, all: 12.2; 
USCCs, no tax: 11.5.

Industry: Other[B]; 
FCCs, all: 12.1; 
FCCs, no tax: 14.0; 
USCCs, all: 20.2; 
USCCs, no tax: 19.7.

Industry: Total; 
FCCs, all: 100.0; 
FCCs, no tax: 100.0; 
USCCs, all: 100.0; 
USCCs, no tax: 100.0.

Source: GAO analysis of IRS data.

Note: Columns may not sum to 100 because of rounding.

[A] Differences between FCCs and USCCs reporting no tax liability are 
not statistically significant.

[B] Other includes transportation and public utilities; mining; 
construction; agriculture, forestry, and fishing; and other trades.

[End of table]

The concentration across industries did not vary much from year to year 
during the reporting period. (See tables 13 and 14 in app. I for year-
to-year comparison.):

In 2000, all large FCCs and large FCCs reporting no tax liability were 
concentrated in the wholesale trade and manufacturing sector. In 
contrast, large USCCs were concentrated in the financial services 
industry. (See table 3.) The distribution of large FCCs and USCCs among 
industry sectors across the years 1996 through 1999 reflects that of 
2000. (See tables 15 and 16 in app. I.):


Table 3: Estimated Percentage Distribution of Large FCCs and USCCs by 
Major Industry, Tax Year 2000:

Industry: Manufacturing; 
FCCs, all: 38.5; 
FCCs, no tax: 38.9; 
USCCs, all: 19.5; 
USCCs, no tax: 14.6.

Industry: Wholesale trade; 
FCCs, all: 26.4; 
FCCs, no tax: 21.2; 
USCCs, all: 11.1; 
USCCs, no tax: 6.3.

Industry: Financial services; 
FCCs, all: 14.1; 
FCCs, no tax: 15.5; 
USCCs, all: 37.2; 
USCCs, no tax: 51.8.

Industry: Nonfinancial services; 
FCCs, all: 9.0; 
FCCs, no tax: 11.1[A]; 
USCCs, all: 11.4; 
USCCs, no tax: 12.0[A].

Industry: Retail; 
FCCs, all: 3.6; 
FCCs, no tax: 3.6; 
USCCs, all: 10.6; 
USCCs, no tax: 7.0.

Industry: Other[B]; 
FCCs, all: 8.4; 
FCCs, no tax: 9.7; 
USCCs, all: 10.3; 
USCCs, no tax: 8.2.

Industry: Total; 
FCCs, all: 100.0; 
FCCs, no tax: 100.0; 
USCCs, all: 100.1; 
USCCs, no tax: 99.9. 

Source: GAO analysis of IRS data.

Note: Columns may not sum to 100 because of rounding.

[A] Differences between large FCCs and large USCCs reporting no tax 
liability are not statistically significant.

[B] Other includes transportation and public utilities; mining; 
construction; agriculture, forestry, and fishing; and other trades.

[End of table]

Differences in cost ratios across industries are possible explanations 
for why industry concentration might affect the reported tax 
liabilities of FCCs and USCCs. Cost differences could affect profits 
and thus tax liabilities. For example, higher cost of goods sold 
relative to receipts could contribute to lower taxable income relative 
to receipts and, consequently, to lower tax liability relative to 
receipts. Tables 19 and 20 in appendix I show several types of cost 
ratios by major industry groups for 2000.

After Controlling for Age and Industry, Differences Remained in FCCs 
and USCCs:

After controlling for age and industry concentration, we estimate that 
all FCCs remained more likely than all USCCs to have reported no tax 
liability from 1996 through 2000. However, consistent with our earlier 
comparisons, all FCCs were significantly less likely than all USCCs to 
have reported tax liabilities of less than 5 percent of their total 
incomes, after controlling for the same factors. For an explanation of 
the simple statistical model used to control for age and industry 
concentration or for details of the regression results, see appendix 
II.

For large corporations, estimated differences in tax liabilities 
between FCCs and USSCs after controlling for age and industry were 
generally smaller than the comparisons without controlling for these 
two factors. These results imply that age and industry may explain some 
of the differences between large FCCs and large USCCs in reporting no 
tax liability or less than 5 percent of tax liability relative to total 
income. As reported in the earlier in this report, large FCCs were in 
all years less likely than large USCCs to report no tax liability or 
less than 5 percent in tax liability. After controlling for age and 
industry concentration, there are less systematic differences between 
FCCs and USCCs in their likelihood of reporting either no tax liability 
or tax liability of less than 5 percent.

Agency Comments:

We provided a draft of this report to the IRS for its comments. On 
February 18, IRS provided comments via e-mail on technical issues, 
which we incorporated into this report where appropriate.

As arranged with your offices, unless you publicly announce its 
contents earlier, we plan no further distribution of this report until 
30 days after its date. At that time, we will then send copies to the 
Commissioner of Internal Revenue and other interested parties. We will 
also make copies available to others on request. In addition, this 
report will be available at no charge on GAO's Web site at  
[Hyperlink, http://www.gao.gov].

If you have any questions concerning this report, please contact me at 
(202) 512-9110 or at [Hyperlink, whitej@gao.gov] or Ralph Block at 
(415) 904-2150. Key contributors to this report are listed in appendix 
III.

Signed by: 

James R. White Director, Tax Issues:

[End of section]

Appendixes: 

Appendix I: Additional Tables:

The tables in this statistical appendix supplement those in the letter. 
All the data were obtained from Internal Revenue Service's (IRS) 
Statistics of Income (SOI) corporate data samples for tax years 1996 
through 2000. The tables in this appendix provide population estimates. 
After each table, notes indicate the sampling errors. We are confident 
the true estimates would be within these percentage points in 95 out of 
every 100 samples. Finally, we conducted tests to determine if there 
were significant differences between all FCCs and USCCs, between FCCs 
and USCCs reporting no tax liability, between large FCCs and USCCs, and 
between large FCCs and USCCs reporting no tax liability. The 
comparisons that were not statistically significant are noted in each 
table.

Table 4: Estimated Number and Percentage of Returns for FCCs and USCCs 
Reporting No Tax Liability:

Tax year: 1996; 
FCC returns: Number: 46,791; 
FCC returns: Percentage: 67.6; 
USCC returns: Number: 1,360,566; 
USCC returns: Percentage: 60.3.

Tax year: 1997; 
FCC returns: Number: 50,625; 
FCC returns: Percentage: 71.7; 
USCC returns: Number: 1,331,638; 
USCC returns: Percentage: 60.9.

Tax year: 1998; 
FCC returns: Number: 50,671; 
FCC returns: Percentage: 71.8; 
USCC returns: Number: 1,335,000; 
USCC returns: Percentage: 61.0.

Tax year: 1999; 
FCC returns: Number: 50,149; 
FCC returns: Percentage: 72.3; 
USCC returns: Number: 1,310,280; 
USCC returns: Percentage: 61.2.

Tax year: 2000; 
FCC returns: Number: 50,688; 
FCC returns: Percentage: 73.3; 
USCC returns: Number: 1,332,239; 
USCC returns: Percentage: 63.0.

Total; 
FCC returns: Number: 248,924; 
FCC returns: Percentage: 71.3; 
USCC returns: Number: 6,669,723; 
USCC returns: Percentage: 61.3.

Source: GAO analysis of IRS data.

Notes: The number of returns consists of population estimates based on 
IRS's sample of corporate tax returns. Percentages are the ratio of 
FCCs and USCCs reporting no tax liability to all (those reporting 
positive and no tax liability) FCCs and USCCs, respectively. Percentage 
estimates for FCCs have sampling errors of less than (+/-) 4 percentage 
points; percentage estimates of USCCs have sampling errors of less 
than (+/-) 1 percentage points.

[End of table]

Table 5: Estimated Percentage Distribution of FCCs and USCCs by Tax 
Liability as Share of Total Income, Tax Years 1996-2000:

FCCs: No tax liability; 
1996: 67.6; 
1997: 71.7; 
1998: 71.8; 
1999: 72.3; 
2000: 73.3.

FCCs: Greater than 0% but lower than 5%; 
1996: 21.0; 
1997: 16.8; 
1998: 17.4; 
1999: 18.0; 
2000: 15.2.

FCCs: 5% or more but less than 10%; 
1996: 5.0; 
1997: 5.0[A]; 
1998: 4.5[A]; 
1999: 4.4[A]; 
2000: 4.2[A].

FCCs: 10% or more but less than 15%; 
1996: 3.0; 
1997: 3.6; 
1998: 3.3; 
1999: 2.5[A]; 
2000: 3.4.

FCCs: 15% or more but less than 30%; 
1996: 2.9; 
1997: 2.6; 
1998: 2.2; 
1999: 2.5; 
2000: 3.0.

FCCs: 30% or more; 
1996: 0.6; 
1997: 0.3; 
1998: 0.8; 
1999: 0.4; 
2000: 0.8.

FCCs: Total; 
1996: 100.1; 
1997: 100.0; 
1998: 100.0; 
1999: 100.1; 
2000: 99.9.

USCCs: No tax liability; 
1996: 60.3; 
1997: 60.9; 
1998: 61.0; 
1999: 61.2; 
2000: 63.0.

USCCs: Greater than 0% but lower than 5%; 
1996: 33.7; 
1997: 32.7; 
1998: 32.4; 
1999: 32.2; 
2000: 30.9.

USCCs: 5% or more but less than 10%; 
1996: 3.5; 
1997: 3.8[A]; 
1998: 3.9[A]; 
1999: 3.7[A]; 
2000: 3.4[A].

USCCs: 10% or more but less than 15%; 
1996: 1.7; 
1997: 1.8; 
1998: 1.8; 
1999: 2.1[A]; 
2000: 1.8.

USCCs: 15% or more but less than 30%; 
1996: 0.6; 
1997: 0.7; 
1998: 0.8; 
1999: 0.7; 
2000: 0.7.

USCCs: 30% or more; 
1996: 0.1; 
1997: 0.1; 
1998: 0.1; 
1999: 0.1; 
2000: 0.1.

USCCs: Total; 
1996: 99.9; 
1997: 100.0; 
1998: 100.0; 
1999: 100.0; 
2000: 99.9.

Source: GAO analysis of IRS data.

Notes: Columns may not sum to 100 because of rounding. All percentage 
estimates have sampling errors of less than (+/-) 4 percentage points.

[A] Differences between FCCs and USCCs are not statistically 
significant.

[End of table]

Table 6: Estimated Percentage Distribution of Large FCCs and USCCs by 
Tax Liability as Share of Total Income, Tax Years 1996-2000:

Large FCCs: No tax liability; 
1996: 29.1; 
1997: 28.2; 
1998: 31.3; 
1999: 33.8; 
2000: 37.5.

Large FCCs: Greater than 0% but lower than 5%; 
1996: 45.5; 
1997: 43.9; 
1998: 43.3; 
1999: 40.7; 
2000: 38.1.

Large FCCs: 5% or more but less than 10%; 
1996: 15.6; 
1997: 16.3; 
1998: 15.5; 
1999: 14.7; 
2000: 13.9.

Large FCCs: 10% or more but less than 15%; 
1996: 5.6; 
1997: 7.7; 
1998: 5.9; 
1999: 6.0; 
2000: 5.8.

Large FCCs: 15% or more but less than 30%; 
1996: 3.7; 
1997: 3.8; 
1998: 3.6; 
1999: 4.4; 
2000: 4.2.

Large FCCs: 30% or more; 
1996: 0.3; 
1997: 0.2; 
1998: 0.4; 
1999: 0.4; 
2000: 0.5.

Large FCCs: Total; 
1996: 99.8; 
1997: 100.1; 
1998: 100.0; 
1999: 100.0; 
2000: 100.0.

Large USCCs: No tax liability; 
1996: 32.7; 
1997: 35.5; 
1998: 37.8; 
1999: 40.9; 
2000: 45.3.

Large USCCs: Greater than 0% but lower than 5%; 
1996: 42.9; 
1997: 40.0; 
1998: 39.9; 
1999: 38.4; 
2000: 36.7.

Large USCCs: 5% or more but less than 10%; 
1996: 17.7; 
1997: 17.8; 
1998: 16.5; 
1999: 15.4; 
2000: 13.1.

Large USCCs: 10% or more but less than 15%; 
1996: 4.8; 
1997: 4.9; 
1998: 4.1; 
1999: 3.6; 
2000: 3.2.

Large USCCs: 15% or more but less than 30%; 
1996: 1.8; 
1997: 1.7; 
1998: 1.5; 
1999: 1.4; 
2000: 1.4.

Large USCCs: 30% or more; 
1996: 0.2; 
1997: 0.2; 
1998: 0.2; 
1999: 0.3; 
2000: 0.3.

Large USCCs: Total; 
1996: 100.1; 
1997: 100.1; 
1998: 100.0; 
1999: 100.0; 
2000: 100.0.

Source: GAO analysis of IRS data.

Notes: "Large" FCCs or USCCs are those with assets of at least $250 
million or gross receipts of at least $50 million in constant 2000 
dollars. Columns may not sum to 100 because of rounding. All percentage 
estimates have sampling errors of less than (+/-) 2 percentage points.

[End of table]

Table 7: Estimated Average Tax Liability Per $1,000 of Gross Receipts 
for All and Large FCCs and USCCs, Tax Years 1996-2000:

Tax year: 1996; 
FCCs, all: $10.62; 
USCCs, all: $16.11; 
FCCs, large: $10.06; 
USCCs, large: $18.82.

Tax year: 1997; 
FCCs, all: 12.23; 
USCCs, all: 16.28; 
FCCs, large: 11.79; 
USCCs, large: 18.76.

Tax year: 1998; 
FCCs, all: 10.77; 
USCCs, all: 15.67; 
FCCs, large: 10.24; 
USCCs, large: 17.91.

Tax year: 1999; 
FCCs, all: 12.49; 
USCCs, all: 15.02; 
FCCs, large: 12.09; 
USCCs, large: 16.99.

Tax year: 2000; 
FCCs, all: 11.88; 
USCCs, all: 14.75; 
FCCs, large: 11.52; 
USCCs, large: 16.65.

Source: GAO analysis of IRS data.

Notes: Estimates in the first, third, and fourth columns have sampling 
errors of less than (+/-) $0.30; estimates in the second column have 
sampling errors of less than (+/-) $0.20.

[End of table]

Table 8: Profile of FCCs and USCCs by Estimated Amount of Income Tax 
Liability, Tax Year 2000:

Distribution by income tax liability: FCCs: No tax liability; 
Number of returns: 50,688; 
Percentage of returns: 73.3; 
Average gross receipts (dollars in millions): $15; 
Average income tax liability (dollars in millions): [A].

Distribution by income tax liability: FCCs: $1 or more but less than 
$100,000; 
Number of returns: 12,577; 
Percentage of returns: 18.2; 
Average gross receipts (dollars in millions): 6; 
Average income tax liability (dollars in millions): $0.02.

Distribution by income tax liability: FCCs: $100,000 or more but less 
than $1 million; 
Number of returns: 4,193; 
Percentage of returns: 6.1; 
Average gross receipts (dollars in millions): 48[B]; 
Average income tax liability (dollars in millions): 0.35.

Distribution by income tax liability: FCCs: $1 million or more; 
Number of returns: 1,681; 
Percentage of returns: 2.4; 
Average gross receipts (dollars in millions): 741[B]; 
Average income tax liability (dollars in millions): 15.01[C].

Distribution by income tax liability: FCCs: Total; 
Number of returns: : 69,139; 
Percentage of returns: 100; 
Average gross receipts (dollars in millions): $33; 
Average income tax liability (dollars in millions): $0.39.

Distribution by income tax liability: USCCs: No tax liability; 
Number of returns: 1,332,239; 
Percentage of returns: 63.0; 
Average gross receipts (dollars in millions): $2; 
Average income tax liability (dollars in millions): [A].

Distribution by income tax liability: USCCs: $1 or more but less than 
$100,000; 
Number of returns: 740,639; 
Percentage of returns: 35.0; 
Average gross receipts (dollars in millions): 2; 
Average income tax liability (dollars in millions): $0.01.

Distribution by income tax liability: USCCs: $100,000 or more but less 
than $1 million; 
Number of returns: 33,423; 
Percentage of returns: : 1.6; 
Average gross receipts (dollars in millions): 24; 
Average income tax liability (dollars in millions): 0.29.

Distribution by income tax liability: USCCs: $1 million or more; 
Number of returns: 7,387; 
Percentage of returns: 0.3; 
Average gross receipts (dollars in millions): 980[B]; 
Average income tax liability (dollars in millions): 21.53[C].

Distribution by income tax liability: USCCs: Total; 
Number of returns: 2,113,689; 
Percentage of returns: 99.9; 
Average gross receipts (dollars in millions): $6; 
Average income tax liability (dollars in millions): $0.08.

Source: GAO analysis of IRS data.

Notes: Columns may not sum to 100 because of rounding. Estimates in the 
second column have sampling errors of less than (+/-) 2 percentage 
points; 
estimates in the third column have sampling errors of less than (+/-) 
$3 million dollars except where noted; estimates in the fourth column 
have sampling errors of less than (+/-) $.03 million dollars except 
where noted.

[A] Data not applicable.

[B] Sampling errors may be as high as (+/-) $13 million dollars.

[C] Sampling errors may be as high as (+/-) $0.2 million dollars.

[End of table]

Table 9: Profile of Large FCCs and USCCs by Estimated Amount of Income 
Tax Liability, Tax Year 2000:

Distribution by income tax liability: Large FCCs: No tax liability; 
Number of returns: 1,251; 
Percentage of returns: 37.5; 
Average gross receipts (dollars in millions): $532; 
Average income tax liability (dollars in millions): [A].

Distribution by income tax liability: Large FCCs: $1 or more but less 
than $100,000; 
Number of returns: 289; 
Percentage of returns: 8.7; 
Average gross receipts (dollars in millions): 143[B]; 
Average income tax liability (dollars in millions): $0.04.

Distribution by income tax liability: Large FCCs: $100,000 or more but 
less than $1 million; 
Number of returns: 630; 
Percentage of returns: 18.9; 
Average gross receipts (dollars in millions): 260; 
Average income tax liability (dollars in millions): 0.45.

Distribution by income tax liability: Large FCCs: $1 million or more; 
Number of returns: 1,165; 
Percentage of returns: 34.9; 
Average gross receipts (dollars in millions): 1,061; 
Average income tax liability (dollars in millions): 20.57.

Distribution by income tax liability: Large FCCs: Total; 
Number of returns: 3,335; 
Percentage of returns: 100.0; 
Average gross receipts (dollars in millions): 632; 
Average income tax liability (dollars in millions): 7.28.

Distribution by income tax liability: Large USCCs: No tax liability; 
Number of returns: 8,335; 
Percentage of returns: 45.3; 
Average gross receipts (dollars in millions): $182; 
Average income tax liability (dollars in millions): [A].

Distribution by income tax liability: Large USCCs: $1 or more but less 
than $100,000; 
Number of returns: 1,476; 
Percentage of returns: 8.0; 
Average gross receipts (dollars in millions): 132[B]; 
Average income tax liability (dollars in millions): $0.04.

Distribution by income tax liability: Large USCCs: $100,000 or more 
but less than $1 million; 
Number of returns: 3,152; 
Percentage of returns: 17.1; 
Average gross receipts (dollars in millions): 149; 
Average income tax liability (dollars in millions): 0.44.

Distribution by income tax liability: Large USCCs: $1 million or more; 
Number of returns: 5,427; 
Percentage of returns: 29.5; 
Average gross receipts (dollars in millions): 1,328; 
Average income tax liability (dollars in millions): 28.54.

Distribution by income tax liability: Large USCCs: Total; 
Number of returns: 18,390; 
Percentage of returns: 99.9; 
Average gross receipts (dollars in millions): $511; 
Average income tax liability (dollars in millions): $8.50.

Source: GAO analysis of IRS data.

Notes: Columns may not sum to 100 because of rounding. Estimates in the 
second column have sampling errors of less than (+/-) 1 percentage 
point; estimates in the third column have sampling errors of less than 
(+/-) $17 million dollars except where noted; estimates in the fourth 
column have sampling errors of less than (+/-) $0.3 million dollars 
except where noted.

[A] Data not applicable.

[B] Differences between large FCCs and large USCCs are not 
statistically significant.

[End of table]

Table 10: Estimated FCCs and USCCs Reporting No Tax Liability That Are 
Large and Small as a Percentage of All FCCs and USCCs, Tax Years 1996-
2000:

Tax year: 1996; 
Number: Large FCCs: 841; 
Percentage: Large FCCs: 1.8; 
Number: Large USCCs: 5,520; 
Percentage: Large USCCs: 0.4.

Tax year: 1997; 
Number: Large FCCs: 818; 
Percentage: Large FCCs: 1.6; 
Number: Large USCCs: 6,247; 
Percentage: Large USCCs: 0.5.

Tax year: 1998; 
Number: Large FCCs: 944; 
Percentage: Large FCCs: 1.9; 
Number: Large USCCs: 6,674; 
Percentage: Large USCCs: 0.5.

Tax year: 1999; 
Number: Large FCCs: 1,060; 
Percentage: Large FCCs: 2.1; 
Number: Large USCCs: 7,435; 
Percentage: Large USCCs: 0.6.

Tax year: 2000; 
Number: Large FCCs: 1,251; 
Percentage: Large FCCs: 2.5; 
Number: Large USCCs: 8,335; 
Percentage: Large USCCs: 0.6.

Total; 
Number: Large FCCs: 4,913; 
Percentage: Large FCCs: 2.0; 
Number: Large USCCs: 34,210; 
Percentage: Large USCCs: 0.5.

Tax year: 1996; 
Number: Small FCCs: 45,951; 
Percentage: Small FCCs: 98.2; 
Number: Small USCCs: 1,355,046; 
Percentage: Small USCCs: 99.6.

Tax year: 1997; 
Number: Small FCCs: 49,807; 
Percentage: Small FCCs: 98.4; 
Number: Small USCCs: 1,325,390; 
Percentage: Small USCCs: 99.5.

Tax year: 1998; 
Number: Small FCCs: 49,727; 
Percentage: Small FCCs: 98.1; 
Number: Small USCCs: 1,328,327; 
Percentage: Small USCCs: 99.5.

Tax year: 1999; 
Number: Small FCCs: 49,089; 
Percentage: Small FCCs: 97.9; 
Number: Small USCCs: 1,302,845; 
Percentage: Small USCCs: 99.4.

Tax year: 2000; 
Number: Small FCCs: 49,437; 
Percentage: Small FCCs: 97.5; 
Number: Small USCCs: 1,323,904; 
Percentage: Small USCCs: 99.4.

Total; 
Number: Small FCCs: 24,401; 
Percentage: Small FCCs: 98.0; 
Number: Small USCCs: 6,635,513; 
Percentage: Small USCCs: 99.5.

Source: GAO analysis of IRS data.

Notes: "Small" FCCs or USCCs are those with assets of less than $250 
million or gross receipts of less than $50 million in constant 2000 
dollars. Percentages are the ratio of large FCCs and large USCCs 
reporting no tax liability to all (large and small) FCCs and USCCs, 
respectively, and of small FCCs and small USCCs reporting no tax 
liability to all FCCs and USCCs, respectively. Percentage estimates for 
FCCs have sampling errors of less than (+/-) .5 percentage points; 
percentages estimates for USCCs have sampling errors of less than 
(+/-) .05 percentage points.

[End of table]

Table 11: Estimated Percentages of FCCs and USCCs That Were New, Tax 
Years 1996-2000:

Tax year: 1996; 
FCCs, all: 30.2; 
USCCs, all: 21.8; 
FCCs, no tax: 29.9; 
USCCs, no tax: 23.4.

Tax year: 1997; 
FCCs, all: 25.3; 
USCCs, all: 21.0; 
FCCs, no tax: 24.9[A]; 
USCCs, no tax: 23.0[A].

Tax year: 1998; 
FCCs, all: 24.3; 
USCCs, all: 20.3; 
FCCs, no tax: 25.0[A]; 
USCCs, no tax: 22.3[A].

Tax year: 1999; 
FCCs, all: 23.6; 
USCCs, all: 19.5; 
FCCs, no tax: 22.6[A]; 
USCCs, no tax: 21.8[A].

Tax year: 2000; 
FCCs, all: 22.3; 
USCCs, all: 18.5; 
FCCs, no tax: 21.8[A]; 
USCCs, no tax: 20.6[A].

Source: GAO analysis of IRS data.

Notes: "New" includes FCCs and USCCs incorporated within 3 years. 
Estimates in the second column have sampling errors of less than (+/-) 
1 percentage point; estimates in the fourth column have sampling errors 
of less than (+/-) 2 percentage points; estimates in the first and 
third columns have sampling errors of less than (+/-) 6 percentage 
points.

[A] Differences between FCCs and USCCs reporting no tax liability are 
not statistically significant.

[End of table]

Table 12: Estimated Percentages of Large FCCs and USCCs That Were New, 
Tax Years 1996-2000:

Tax year: 1996; 
FCCs, all: 8.8[A]; 
USCCs, all: 8.6[A]; 
FCCs, no tax: 12.9[A]; 
USCCs, no tax: 12.2[A].

Tax year: 1997; 
FCCs, all: 11.0; 
USCCs, all: 9.2; 
FCCs, no tax: 13.8[A]; 
USCCs, no tax: 12.8[A].

Tax year: 1998; 
FCCs, all: 12.4; 
USCCs, all: 10.7; 
FCCs, no tax: 16.1; 
USCCs, no tax: 14.5.

Tax year: 1999; 
FCCs, all: 13.4; 
USCCs, all: 10.8; 
FCCs, no tax: 18.1; 
USCCs, no tax: 15.2.

Tax year: 2000; 
FCCs, all: 13.6; 
USCCs, all: 9.5; 
FCCs, no tax: 16.8; 
USCCs, no tax: 12.6.

Source: GAO analysis of IRS data.

Note: Estimates have sampling errors in the third column of less than 
(+/-) 2 percentage points; the first, second, and fourth columns have 
sampling errors of less than (+/-) 1 percentage point.

[A] Differences between FCCs and USCCs reporting no tax liability are 
not statistically significant.

[End of table]
 

Table 13: Estimated Percentage Distribution of FCCs and USCCs by Major 
Industry, Tax Years 1996-2000:

Industry: Manufacturing; 
1996: FCCs: 9.2[A]; 
1996: USCCs: 7.9[A]; 
1997: FCCs: 10.3; 
1997: USCCs: 7.5; 
1998: FCCs: 9.9; 
1998: USCCs: 7.5; 
1999: FCCs: 9.7; 
1999: USCCs: 7.2; 
2000: FCCs: 10.6; 
2000: USCCs: 6.7.

Industry: Wholesale trade; 
1996: FCCs: 24.8; 
1996: USCCs: 8.8; 
1997: FCCs: 22.3; 
1997: USCCs: 8.7; 
1998: FCCs: 21.6; 
1998: USCCs: 8.0; 
1999: FCCs: 22.5; 
1999: USCCs: 8.1; 
2000: FCCs: 22.2; 
2000: USCCs: 8.2.

Industry: Financial services; 
1996: FCCs: 36.4; 
1996: USCCs: 15.1; 
1997: FCCs: 37.0; 
1997: USCCs: 15.4; 
1998: FCCs: 34.7; 
1998: USCCs: 15.1; 
1999: FCCs: 33.7; 
1999: USCCs: 15.3; 
2000: FCCs: 31.8; 
2000: USCCs: 15.2.

Industry: Nonfinancial services; 
1996: FCCs: 16.3; 
1996: USCCs: 32.4; 
1997: FCCs: 16.9; 
1997: USCCs: 32.9; 
1998: FCCs: 17.0; 
1998: USCCs: 36.9; 
1999: FCCs: 16.2; 
1999: USCCs: 36.9; 
2000: FCCs: 18.5; 
2000: USCCs: 37.5.

Industry: Retail; 
1996: FCCs: 4.8; 
1996: USCCs: 16.1; 
1997: FCCs: 6.1; 
1997: USCCs: 16.1; 
1998: FCCs: 5.7; 
1998: USCCs: 12.5; 
1999: FCCs: 4.7; 
1999: USCCs: 12.2; 
2000: FCCs: 4.8; 
2000: USCCs: 12.2.

Industry: Other[B]; 
1996: FCCs: 8.5; 
1996: USCCs: 19.7; 
1997: FCCs: 7.4; 
1997: USCCs: 19.3; 
1998: FCCs: 11.1; 
1998: USCCs: 19.9; 
1999: FCCs: 13.3; 
1999: USCCs: 20.4; 
2000: FCCs: 12.1; 
2000: USCCs: 20.2.

Total; 
1996: FCCs: 100.0; 
1996: USCCs: 100.0; 
1997: FCCs: 100.0; 
1997: USCCs: 99.9; 
1998: FCCs: 100.0; 
1998: USCCs: 99.9; 
1999: FCCs: 100.1; 
1999: USCCs: 100.1; 
2000: FCCs: 100.0; 
2000: USCCs: 100.0.

Source: GAO analysis of IRS data.

Notes: Columns may not sum to 100 because of rounding. Estimates have 
sampling errors for FCCs of less than (+/-) 4 percentage points; 
estimates for USCCs have sampling errors of less than (+/-) 1 
percentage point.

[A] Differences between FCCs and USCCs are not statistically 
significant.

[B] Other includes transportation and public utilities; 
mining; 
construction; 
agriculture, forestry, and fishing; 
and other trades.

[End of table]
 

Table 14: Estimated Percentage Distribution of FCCs and USCCs Reporting 
No Tax Liability by Major Industry, Tax Years 1996-2000:

Industry: Manufacturing; 
1996: FCCs: 6.5[A]; 
1996: USCCs: 7.4[A]; 
1997: FCCs: 8.2[A]; 
1997: USCCs: 7.0[A]; 
1998: FCCs: 7.7[A]; 
1998: USCCs: 7.0[A]; 
1999: FCCs: 7.0[A]; 
1999: USCCs: 6.7[A]; 
2000: FCCs: 7.5[A]; 
2000: USCCs: 6.6[A].

Industry: Wholesale trade; 
1996: FCCs: 23.6; 
1996: USCCs: 8.0; 
1997: FCCs: 20.8; 
1997: USCCs: 7.8; 
1998: FCCs: 19.6; 
1998: USCCs: 7.4; 
1999: FCCs: 20.1; 
1999: USCCs: 7.2; 
2000: FCCs: 20.5; 
2000: USCCs: 7.4.

Industry: Financial services; 
1996: FCCs: 40.8; 
1996: USCCs: 14.3; 
1997: FCCs: 40.9; 
1997: USCCs: 14.5; 
1998: FCCs: 37.5; 
1998: USCCs: 14.8; 
1999: FCCs: 37.7; 
1999: USCCs: 14.7; 
2000: FCCs: 34.6; 
2000: USCCs: 14.3.

Industry: Nonfinancial services; 
1996: FCCs: 14.7; 
1996: USCCs: 35.1; 
1997: FCCs: 15.0; 
1997: USCCs: 35.8; 
1998: FCCs: 16.9; 
1998: USCCs: 40.3; 
1999: FCCs: 16.6; 
1999: USCCs: 40.0; 
2000: FCCs: 18.5; 
2000: USCCs: 40.5.

Industry: Retail; 
1996: FCCs: 5.4; 
1996: USCCs: 16.2; 
1997: FCCs: 7.4; 
1997: USCCs: 16.3; 
1998: FCCs: 6.2; 
1998: USCCs: 11.4; 
1999: FCCs: 4.9; 
1999: USCCs: 11.3; 
2000: FCCs: 4.9; 
2000: USCCs: 11.5.

Industry: Other[B]; 
1996: FCCs: 9.1; 
1996: USCCs: 19.0; 
1997: FCCs: 7.6; 
1997: USCCs: 18.7; 
1998: FCCs: 12.1; 
1998: USCCs: 19.0; 
1999: FCCs: 13.7; 
1999: USCCs: 20.1; 
2000: FCCs: 14.0; 
2000: USCCs: 19.7.

Total; 
1996: FCCs: 100.1; 
1996: USCCs: 100.0; 
1997: FCCs: 99.9; 
1997: USCCs: 100.1; 
1998: FCCs: 100.0; 
1998: USCCs: 99.9; 
1999: FCCs: 100.0; 
1999: USCCs: 100.0; 
2000: FCCs: 100.0; 
2000: USCCs: 100.0.

Source: GAO analysis of IRS data.

Notes: Columns may not sum to 100 because of rounding. Estimates for 
FCCs have sampling errors of less than (+/-) 6 percentage points; 
estimates for USCCs have sampling errors of less than (+/-) 2 
percentage points.

[A] Differences between FCCs and USCCs are not statistically 
significant.

[B] Other includes transportation and public utilities; 
mining; 
construction; 
agriculture, forestry, and fishing; 
and other trades.

[End of table]

Table 15: Estimated Percentage Distribution of Large FCCs and USCCs by 
Major Industry, Tax Years 1996-2000:

Industry: Manufacturing; 
1996: FCCs: 39.0; 
1996: USCCs: 24.1; 
1997: FCCs: 40.0; 
1997: USCCs: 23.2; 
1998: FCCs: 40.0; 
1998: USCCs: 21.8; 
1999: FCCs: 39.5; 
1999: USCCs: 20.3; 
2000: FCCs: 38.5; 
2000: USCCs: 19.5.

Industry: Wholesale trade; 
1996: FCCs: 28.5; 
1996: USCCs: 12.7; 
1997: FCCs: 28.1; 
1997: USCCs: 11.9; 
1998: FCCs: 26.2; 
1998: USCCs: 10.7; 
1999: FCCs: 26.1; 
1999: USCCs: 11.1; 
2000: FCCs: 26.4; 
2000: USCCs: 11.1.

Industry: Financial services; 
1996: FCCs: 14.1; 
1996: USCCs: 32.5; 
1997: FCCs: 13.7; 
1997: USCCs: 33.9; 
1998: FCCs: 14.4; 
1998: USCCs: 36.0; 
1999: FCCs: 14.4; 
1999: USCCs: 36.9; 
2000: FCCs: 14.1; 
2000: USCCs: 37.2.

Industry: Nonfinancial services; 
1996: FCCs: 7.4; 
1996: USCCs: 8.1; 
1997: FCCs: 7.1; 
1997: USCCs: 9.0; 
1998: FCCs: 7.3; 
1998: USCCs: 9.8; 
1999: FCCs: 8.2; 
1999: USCCs: 11.0; 
2000: FCCs: 9.0; 
2000: USCCs: 11.4.

Industry: Retail; 
1996: FCCs: 3.7; 
1996: USCCs: 12.2; 
1997: FCCs: 3.7; 
1997: USCCs: 11.6; 
1998: FCCs: 4.3; 
1998: USCCs: 11.3; 
1999: FCCs: 3.6; 
1999: USCCs: 10.7; 
2000: FCCs: 3.6; 
2000: USCCs: 10.6.

Industry: Other[A]; 
1996: FCCs: 7.3; 
1996: USCCs: 10.4; 
1997: FCCs: 7.3; 
1997: USCCs: 10.3; 
1998: FCCs: 7.7; 
1998: USCCs: 10.4; 
1999: FCCs: 8.1; 
1999: USCCs: 10.1; 
2000: FCCs: 8.4; 
2000: USCCs: 10.3.

Total; 
1996: FCCs: 100.0; 
1996: USCCs: 100.0; 
1997: FCCs: 99.9; 
1997: USCCs: 99.9; 
1998: FCCs: 99.9; 
1998: USCCs: 100.0; 
1999: FCCs: 99.9; 
1999: USCCs: 100.1; 
2000: FCCs: 100.0; 
2000: USCCs: 100.1.

Source: GAO analysis of IRS data.

Notes: Columns may not sum to 100 because of rounding. Estimates for 
FCCs have sampling errors of less than (+/-) 2 percent; 
estimates for USCCs have sampling errors of less than (+/-) 1 percent.

[A] Other includes transportation and public utilities; 
mining; 
construction; 
agriculture, forestry, and fishing; 
and other trades.

[End of table]

Table 16: Estimated Percentage Distribution of Large FCCs and USCCs 
Reporting No Tax Liability by Major Industry, Tax Years 1996-2000:

Industry: Manufacturing; 
1996: FCCs: 34.5; 
1996: USCCs: 15.0; 
1997: FCCs: 35.4; 
1997: USCCs: 14.2; 
1998: FCCs: 35.1; 
1998: USCCs: 14.6; 
1999: FCCs: 37.1; 
1999: USCCs: 13.9; 
2000: FCCs: 38.8; 
2000: USCCs: 14.6.

Industry: Wholesale trade; 
1996: FCCs: 27.8; 
1996: USCCs: 7.7; 
1997: FCCs: 26.1; 
1997: USCCs: 7.5; 
1998: FCCs: 24.8; 
1998: USCCs: 5.7; 
1999: FCCs: 22.5; 
1999: USCCs: 5.6; 
2000: FCCs: 21.2; 
2000: USCCs: 6.3.

Industry: Financial services; 
1996: FCCs: 16.3; 
1996: USCCs: 54.4; 
1997: FCCs: 16.1; 
1997: USCCs: 54.7; 
1998: FCCs: 16.7; 
1998: USCCs: 56.8; 
1999: FCCs: 17.4; 
1999: USCCs: 55.9; 
2000: FCCs: 15.5; 
2000: USCCs: 51.8.

Industry: Nonfinancial services; 
1996: FCCs: 7.5[A]; 
1996: USCCs: 7.1[A]; 
1997: FCCs: 8.6[A]; 
1997: USCCs: 8.7[A]; 
1998: FCCs: 8.3[A]; 
1998: USCCs: 9.0[A]; 
1999: FCCs: 9.2; 
1999: USCCs: 11.6; 
2000: FCCs: 11.1[A]; 
2000: USCCs: 12.0[A].

Industry: Retail; 
1996: FCCs: 4.5; 
1996: USCCs: 9.1; 
1997: FCCs: 5.0; 
1997: USCCs: 7.7; 
1998: FCCs: 5.9[A]; 
1998: USCCs: 6.1[A]; 
1999: FCCs: 3.5; 
1999: USCCs: 5.5; 
2000: FCCs: 3.6; 
2000: USCCs: 7.0.

Industry: Other[B]; 
1996: FCCs: 9.5; 
1996: USCCs: 6.7; 
1997: FCCs: 8.8; 
1997: USCCs: 7.1; 
1998: FCCs: 9.1; 
1998: USCCs: 7.8; 
1999: FCCs: 10.4; 
1999: USCCs: 7.6; 
2000: FCCs: 9.7; 
2000: USCCs: 8.2.

Total; 
1996: FCCs: 100.1; 
1996: USCCs: 100.0; 
1997: FCCs: 100.0; 
1997: USCCs: 99.9; 
1998: FCCs: 99.9; 
1998: USCCs: 100.0; 
1999: FCCs: 100.1; 
1999: USCCs: 100.1; 
2000: FCCs: 99.9; 
2000: USCCs: 99.9.

Source: GAO analysis of IRS data.

Notes: Columns may not sum to 100 because of rounding. Estimates for 
FCCs have sampling errors of less than (+/-) 3 percent; estimates for 
USCCs have sampling errors of less than (+/-) 2 percent.

[A] Differences between FCCs and USCCs are not statistically 
significant.

[B] Other includes transportation and public utilities; 
mining; 
construction; 
agriculture, forestry, and fishing; 
and other trades.

[End of table]

Table 17: Estimated Percentage of FCCs and USCCs That Reported No Tax 
Liability in Each Industry, Tax Years 1996-2000:

Tax year: 1996; 
Manufacturing: FCCs: 47.4[AB]; 
Manufacturing: USCCs: 56.8[A]; 
Wholesale trade: FCCs: 64.4; 
Wholesale trade: USCCs: 54.7; 
Financial services: FCCs: 75.6; 
Financial services: USCCs: 56.8; 
Nonfinancial services: FCCs: 60.8[AB]; 
Nonfinancial services: USCCs: 65.5[A]; 
Retail: FCCs: 76.6[AC]; 
Retail: USCCs: 60.7[A].

Tax year: 1997; 
Manufacturing: FCCs: 57.3[A]; 
Manufacturing: USCCs: 56.8[A]; 
Wholesale trade: FCCs: 66.9; 
Wholesale trade: USCCs: 54.4; 
Financial services: FCCs: 79.2; 
Financial services: USCCs: 57.4; 
Nonfinancial services: FCCs: 63.8[AB]; 
Nonfinancial services: USCCs: 66.2[A]; 
Retail: FCCs: 87.3[B]; 
Retail: USCCs: 61.5.

Tax year: 1998; 
Manufacturing: FCCs: 56.1[A]; 
Manufacturing: USCCs: 57.4[A]; 
Wholesale trade: FCCs: 65.1; 
Wholesale trade: USCCs: 56.2; 
Financial services: FCCs: 77.6; 
Financial services: USCCs: 59.8; 
Nonfinancial services: FCCs: 71.0[A]; 
Nonfinancial services: USCCs: 66.6[A]; 
Retail: FCCs: 78.4[B]; 
Retail: USCCs: 55.7.

Tax year: 1999; 
Manufacturing: FCCs: 51.9[A]; 
Manufacturing: USCCs: 57.3[A]; 
Wholesale trade: FCCs: 64.5; 
Wholesale trade: USCCs: 54.0; 
Financial services: FCCs: 81.0; 
Financial services: USCCs: 58.7; 
Nonfinancial services: FCCs: 74.4; 
Nonfinancial services: USCCs: 66.5; 
Retail: FCCs: 75.0[C]; 
Retail: USCCs: 57.0.

Tax year: 2000; 
Manufacturing: FCCs: 51.4; 
Manufacturing: USCCs: 61.7; 
Wholesale trade: FCCs: 67.7; 
Wholesale trade: USCCs: 56.8; 
Financial services: FCCs: 79.8; 
Financial services: USCCs: 59.3; 
Nonfinancial services: FCCs: 73.6[A]; 
Nonfinancial services: USCCs: 68.2[A]; 
Retail: FCCs: 73.8[AC]; 
Retail: USCCs: 59.4[A].

Source: GAO analysis of IRS data.

Note: All estimates have sampling errors of less than (+/-) 10 percent 
except where noted.

[A] Differences between FCCs and USCCs are not statistically 
significant.

[B] Sampling errors may be as high as (+/-) 14 percentage points.

[C] Sampling errors may be as high as (+/-) 23 percentage points.

[End of table]

Table 18: Estimated Percentage of Large FCCs and USCCs That Reported No 
Tax Liability in Each Industry, Tax Years 1996-2000:

Tax year: 1996; 
Manufacturing: FCCs: 25.7; 
Manufacturing: USCCs: 20.3; 
Wholesale trade: FCCs: 28.3; 
Wholesale trade: USCCs: 19.9; 
Financial services: FCCs: 33.7; 
Financial services: USCCs: 54.7; 
Nonfinancial services: FCCs: 29.6[A]; 
Nonfinancial services: USCCs: 28.5[A]; 
Retail: FCCs: 35.1; 
Retail: USCCs: 24.3.

Tax year: 1997; 
Manufacturing: FCCs: 24.9; 
Manufacturing: USCCs: 21.8; 
Wholesale trade: FCCs: 26.2[A]; 
Wholesale trade: USCCs: 22.5[A]; 
Financial services: FCCs: 32.8; 
Financial services: USCCs: 57.3; 
Nonfinancial services: FCCs: 34.3[A]; 
Nonfinancial services: USCCs: 34.3[A]; 
Retail: FCCs: 38.5; 
Retail: USCCs: 23.5.

Tax year: 1998; 
Manufacturing: FCCs: 27.5; 
Manufacturing: USCCs: 25.3; 
Wholesale trade: FCCs: 29.6; 
Wholesale trade: USCCs: 20.0; 
Financial services: FCCs: 36.5; 
Financial services: USCCs: 59.7; 
Nonfinancial services: FCCs: 35.6[A]; 
Nonfinancial services: USCCs: 34.4[A]; 
Retail: FCCs: 42.6; 
Retail: USCCs: 20.5.

Tax year: 1999; 
Manufacturing: FCCs: 31.7; 
Manufacturing: USCCs: 27.9; 
Wholesale trade: FCCs: 29.2; 
Wholesale trade: USCCs: 20.5; 
Financial services: FCCs: 40.6; 
Financial services: USCCs: 62.0; 
Nonfinancial services: FCCs: 37.6; 
Nonfinancial services: USCCs: 43.3; 
Retail: FCCs: 32.7; 
Retail: USCCs: 20.9.

Tax year: 2000; 
Manufacturing: FCCs: 37.9; 
Manufacturing: USCCs: 34.1; 
Wholesale trade: FCCs: 30.1; 
Wholesale trade: USCCs: 25.7; 
Financial services: FCCs: 41.3; 
Financial services: USCCs: 63.2; 
Nonfinancial services: FCCs: 46.0[A]; 
Nonfinancial services: USCCs: 47.9[A]; 
Retail: FCCs: 37.8; 
Retail: USCCs: 30.0.

Source: GAO analysis of IRS data.

Note: All estimates have sampling errors of less than (+/-) 6 
percentage points.

[A] Differences between FCCs and USCCs are not statistically 
significant.

[End of table]

Table 19: Estimated Cost Ratios for All FCCs and USCCs by Major 
Industry, Tax Year 2000:

Industry: FCCs: Manufacturing; 
Cost of goods sold as a percentage of gross receipts: No tax: 76.3; 
Cost of goods sold as a percentage of gross receipts: All: 71.6; 
Purchases as a percentage of gross receipts: No tax: 56.7; 
Purchases as a percentage of gross receipts: All: 56.8; 
Interest as a percentage of gross receipts: No tax: 5.2; 
Interest as a percentage of gross receipts: All: 4.5[A].

Industry: FCCs: Wholesale trade; 
Cost of goods sold as a percentage of gross receipts: No tax: 86.3; 
Cost of goods sold as a percentage of gross receipts: All: 83.3; 
Purchases as a percentage of gross receipts: No tax: 80.2; 
Purchases as a percentage of gross receipts: All: 80.2; 
Interest as a percentage of gross receipts: No tax: 1.6; 
Interest as a percentage of gross receipts: All: 1.7.

Industry: FCCs: Financial services; 
Cost of goods sold as a percentage of gross receipts: No tax: 43.0[B]; 
Cost of goods sold as a percentage of gross receipts: All: 49.2; 
Purchases as a percentage of gross receipts: No tax: 3.4; 
Purchases as a percentage of gross receipts: All: 1.7; 
Interest as a percentage of gross receipts: No tax: 118.8[C]; 
Interest as a percentage of gross receipts: All: 74.9[ C].

Industry: FCCs: Nonfinancial services; 
Cost of goods sold as a percentage of gross receipts: No tax: 50.7; 
Cost of goods sold as a percentage of gross receipts: All: 46.0; 
Purchases as a percentage of gross receipts: No tax: 19.4; 
Purchases as a percentage of gross receipts: All: 16.7; 
Interest as a percentage of gross receipts: No tax: 5.1; 
Interest as a percentage of gross receipts: All: 7.8.

Industry: FCCs: Retail trade; 
Cost of goods sold as a percentage of gross receipts: No tax: 69.1; 
Cost of goods sold as a percentage of gross receipts: All: 71.4; 
Purchases as a percentage of gross receipts: No tax: 60.6; 
Purchases as a percentage of gross receipts: All: 63.1; 
Interest as a percentage of gross receipts: No tax: 2.7; 
Interest as a percentage of gross receipts: All: 2.3.

Industry: FCCs: Other; 
Cost of goods sold as a percentage of gross receipts: No tax: 57.0; 
Cost of goods sold as a percentage of gross receipts: All: 59.7; 
Purchases as a percentage of gross receipts: No tax: 17.7; 
Purchases as a percentage of gross receipts: All: 20.0; 
Interest as a percentage of gross receipts: No tax: 6.5; 
Interest as a percentage of gross receipts: All: 7.2.

Industry: USCCs: Manufacturing; 
Cost of goods sold as a percentage of gross receipts: No tax: 69.2; 
Cost of goods sold as a percentage of gross receipts: All: 67.8; 
Purchases as a percentage of gross receipts: No tax: 45.0; 
Purchases as a percentage of gross receipts: All: 43.8; 
Interest as a percentage of gross receipts: No tax: 4.6; 
Interest as a percentage of gross receipts: All: 4.5[A].

Industry: USCCs: Wholesale trade; 
Cost of goods sold as a percentage of gross receipts: No tax: 81.0; 
Cost of goods sold as a percentage of gross receipts: All: 81.7; 
Purchases as a percentage of gross receipts: No tax: 73.9; 
Purchases as a percentage of gross receipts: All: 78.1; 
Interest as a percentage of gross receipts: No tax: 1.8; 
Interest as a percentage of gross receipts: All: 1.4.

Industry: USCCs: Financial services; 
Cost of goods sold as a percentage of gross receipts: No tax: 56.4[B]; 
Cost of goods sold as a percentage of gross receipts: All: 53.5; 
Purchases as a percentage of gross receipts: No tax: 1.9; 
Purchases as a percentage of gross receipts: All: 1.1; 
Interest as a percentage of gross receipts: No tax: 19.1; 
Interest as a percentage of gross receipts: All: 41.1.

Industry: USCCs: Nonfinancial services; 
Cost of goods sold as a percentage of gross receipts: No tax: 26.0; 
Cost of goods sold as a percentage of gross receipts: All: 30.8; 
Purchases as a percentage of gross receipts: No tax: 11.3; 
Purchases as a percentage of gross receipts: All: 11.3; 
Interest as a percentage of gross receipts: No tax: 2.8; 
Interest as a percentage of gross receipts: All: 3.1.

Industry: USCCs: Retail trade; 
Cost of goods sold as a percentage of gross receipts: No tax: 73.5; 
Cost of goods sold as a percentage of gross receipts: All: 73.1; 
Purchases as a percentage of gross receipts: No tax: 68.3; 
Purchases as a percentage of gross receipts: All: 69.7; 
Interest as a percentage of gross receipts: No tax: 1.7; 
Interest as a percentage of gross receipts: All: 1.4.

Industry: USCCs: Other; 
Cost of goods sold as a percentage of gross receipts: No tax: 49.8; 
Cost of goods sold as a percentage of gross receipts: All: 53.4; 
Purchases as a percentage of gross receipts: No tax: 21.1; 
Purchases as a percentage of gross receipts: All: 22.2; 
Interest as a percentage of gross receipts: No tax: 7.3; 
Interest as a percentage of gross receipts: All: 5.3.

Source: GAO analysis of IRS data.

Note: All estimates have sampling errors of less than (+/-) 3 
percentage points except where noted.

[A] Differences between FCCs and USCCs are not statistically 
significant.

[B] Sampling errors may be as high as (+/-) 5 percentage points.

[C] Sampling errors may be as high as (+/-) 24 percentage points.

[End of table]

Table 20: Estimated Cost Ratios for Large FCCs and USCCs by Major 
Industry, Tax Year 2000:

Industry: FCCs: Manufacturing; 
Cost of goods sold as a percentage of gross receipts: No tax: 76.4; 
Cost of goods sold as a percentage of gross receipts: All: 71.7; 
Purchases as a percentage of gross receipts: No tax: 56.9; 
Purchases as a percentage of gross receipts: All: 57.0; 
Interest as a percentage of gross receipts: No tax: 5.3; 
Interest as a percentage of gross receipts: All: 4.6.

Industry: FCCs: Wholesale trade; 
Cost of goods sold as a percentage of gross receipts: No tax: 87.4; 
Cost of goods sold as a percentage of gross receipts: All: 83.8[A]; 
Purchases as a percentage of gross receipts: No tax: 81.1; 
Purchases as a percentage of gross receipts: All: 80.9[A]; 
Interest as a percentage of gross receipts: No tax: 1.6; 
Interest as a percentage of gross receipts: All: 1.8.

Industry: FCCs: Financial services; 
Cost of goods sold as a percentage of gross receipts: No tax: 45.0[B]; 
Cost of goods sold as a percentage of gross receipts: All: 50.5; 
Purchases as a percentage of gross receipts: No tax: 2.4; 
Purchases as a percentage of gross receipts: All: 1.3; 
Interest as a percentage of gross receipts: No tax: 99.8[C]; 
Interest as a percentage of gross receipts: All: 68.7[B].

Industry: FCCs: Nonfinancial services; 
Cost of goods sold as a percentage of gross receipts: No tax: 52.8; 
Cost of goods sold as a percentage of gross receipts: All: 47.3; 
Purchases as a percentage of gross receipts: No tax: 19.2; 
Purchases as a percentage of gross receipts: All: 16.8; 
Interest as a percentage of gross receipts: No tax: 5.4; 
Interest as a percentage of gross receipts: All: 8.7.

Industry: FCCs: Retail trade; 
Cost of goods sold as a percentage of gross receipts: No tax: 70.2; 
Cost of goods sold as a percentage of gross receipts: All: 71.9; 
Purchases as a percentage of gross receipts: No tax: 60.9; 
Purchases as a percentage of gross receipts: All: 63.4; 
Interest as a percentage of gross receipts: No tax: 2.9; 
Interest as a percentage of gross receipts: All: 2.4.

Industry: FCCs: Other; 
Cost of goods sold as a percentage of gross receipts: No tax: 55.8; 
Cost of goods sold as a percentage of gross receipts: All: 59.9; 
Purchases as a percentage of gross receipts: No tax: 17.5[A]; 
Purchases as a percentage of gross receipts: All: 20.3; 
Interest as a percentage of gross receipts: No tax: 6.7; 
Interest as a percentage of gross receipts: All: 7.5.

Industry: USCCs: Manufacturing; 
Cost of goods sold as a percentage of gross receipts: No tax: 70.0; 
Cost of goods sold as a percentage of gross receipts: All: 68.0; 
Purchases as a percentage of gross receipts: No tax: 45.9; 
Purchases as a percentage of gross receipts: All: 44.0; 
Interest as a percentage of gross receipts: No tax: 5.1; 
Interest as a percentage of gross receipts: All: 4.7.

Industry: USCCs: Wholesale trade; 
Cost of goods sold as a percentage of gross receipts: No tax: 84.6; 
Cost of goods sold as a percentage of gross receipts: All: 84.0[A]; 
Purchases as a percentage of gross receipts: No tax: 77.0; 
Purchases as a percentage of gross receipts: All: 81.0[A]; 
Interest as a percentage of gross receipts: No tax: 2.0; 
Interest as a percentage of gross receipts: All: 1.6.

Industry: USCCs: Financial services; 
Cost of goods sold as a percentage of gross receipts: No tax: 64.0[B]; 
Cost of goods sold as a percentage of gross receipts: All: 56.2; 
Purchases as a percentage of gross receipts: No tax: 1.3; 
Purchases as a percentage of gross receipts: All: 0.9; 
Interest as a percentage of gross receipts: No tax: 18.3; 
Interest as a percentage of gross receipts: All: 42.4.

Industry: USCCs: Nonfinancial services; 
Cost of goods sold as a percentage of gross receipts: No tax: 30.7; 
Cost of goods sold as a percentage of gross receipts: All: 35.4; 
Purchases as a percentage of gross receipts: No tax: 11.0; 
Purchases as a percentage of gross receipts: All: 10.9; 
Interest as a percentage of gross receipts: No tax: 4.9; 
Interest as a percentage of gross receipts: All: 4.6.

Industry: USCCs: Retail trade; 
Cost of goods sold as a percentage of gross receipts: No tax: 71.6; 
Cost of goods sold as a percentage of gross receipts: All: 72.4; 
Purchases as a percentage of gross receipts: No tax: 65.7; 
Purchases as a percentage of gross receipts: All: 69.1; 
Interest as a percentage of gross receipts: No tax: 2.1; 
Interest as a percentage of gross receipts: All: 1.6.

Industry: USCCs: Other; 
Cost of goods sold as a percentage of gross receipts: No tax: 44.0; 
Cost of goods sold as a percentage of gross receipts: All: 51.2; 
Purchases as a percentage of gross receipts: No tax: 18.5[A]; 
Purchases as a percentage of gross receipts: All: 21.4; 
Interest as a percentage of gross receipts: No tax: 10.1; 
Interest as a percentage of gross receipts: All: 6.3.

Source: GAO analysis of IRS data.

Note: All estimates have sampling errors of less than (+/-) 3 
percentage points except where noted.

[A] Differences between large FCCS and USCCs are not statistically 
significant.

[B] Sampling errors may be as high as (+/-) 6 percentage points.

[C] Sampling errors may be as high as (+/-) 23 percentage points. 

[End of table]

[End of section]

Appendix II: Statistical Analysis Using Logistic Regression:

We used the SOI data from IRS's sample of corporate tax returns to 
estimate the differences between FCCs and USCCs in reporting no U.S. 
income tax liability or tax liability of less than 5 percent relative 
to total income. We looked at all of the corporations and separately at 
large corporations in each tax year from 1996 through 2000, and 
calculated odds ratios to estimate the difference between FCCs and 
USCCs.[Footnote 7] We used USCCs as the reference category in our 
calculations, so the odds ratios indicate how much more likely (when 
the ratios exceed 1.0) or less likely (when they are less than 1.0) the 
odds were of FCCs reporting to have no tax liability or tax liability 
of less than 5 percent compared with USCCs. We show these odds ratios 
in the tables 21 and 22 both before and after adjusting them to control 
for the age and industry sector of each corporation. While the 
unadjusted odds ratios can be derived directly from the unadjusted odds 
shown in these tables, the adjusted odds ratios are from logistic 
regression models that were used in each year to estimate the 
difference between FCCs and USSCs after the controls for age and 
industry sector were introduced.[Footnote 8] The following explains how 
odds ratios are calculated and elaborates on the tables in this 
appendix.

The odds on whether FCCs and USCCs report no tax liability or tax 
liability less than 5 percent are somewhat different from, but related 
to, the percentage of each type of corporation reporting no tax 
liability or tax liability of less than 5 percent. The odds of 
reporting no tax liability equal the percentage reporting no tax 
liability divided by the percentage reporting positive tax liability. 
For the sample of all FCCs and USCCs in 1996, for example, 67.6 percent 
of FCCs reported no tax liability. (See table 21.) The odds of an FCC 
reporting no tax liability in that year was 2.08, which equals 67.6/
32.4[Footnote 9] and implies that 2.08 of FCCs reported no tax 
liability for every FCC that reported some tax liability, or that 208 
FCCs reported no tax liability for every 100 FCCs that reported some 
tax liability. Since 60.3 percent of USCCs reported no tax liability in 
1996, the odds of USCCs reporting no tax liability was 1.52, which 
equals 60.3/39.7. The unadjusted ratio of these odds, which is 2.08/
1.52 = 1.37, apart from rounding, implies that FCCs were more likely 
than USCCs to have reported no tax liability by a factor of 1.37. While 
odds are somewhat less familiar than percentages, the use of odds and 
odds ratios are unlike percentages and percentage differences, which 
are unaffected by whether we choose to look at the likelihood of 
whether an outcome does or does not occur, and by how likely or 
unlikely the outcome is across the subgroups we are comparing.

Table 21 shows how different all FCCs and USCCs were, using both 
percentage differences and odds ratios in each year, in terms or 
reporting no tax liability or tax liability of less than 5 percent of 
total income. Both before (unadjusted) and after (adjusted) controlling 
for age and industry sector, in every year FCCs were significantly more 
likely than USSCs to have reported no tax liability, with odds ratios 
ranging from roughly 1.37 to roughly 1.79. At the same time, FCCs were 
significantly less likely than USCCs to have reported tax liability of 
less than 5 percent in all years, with odds ratios ranging from roughly 
0.49 to 0.78.

Table 21: Estimated Percentages and Odds on Reporting No Tax Liability 
and Tax Liability of Less Than 5 Percent of Total Income, between All 
FCCs and USCCs and Odds Ratios Indicating the Difference between FCCs 
and USCCs, before and after Controlling for Age and Industry Sector, 
Tax Years 1996-2000:

Tax year: 1996; 
Percentage reporting no tax liability: FCC: 67.6; 
Percentage reporting no tax liability: USCC: 60.3; 
Odds on reporting no tax liability: FCC: 2.08; 
Odds on reporting no tax liability: USCC: 1.52; 
Odds ratios: Unadjusted: 1.37; 
Odds ratios: Adjusted: 1.47.

Tax year: 1997; 
Percentage reporting no tax liability: FCC: 71.7; 
Percentage reporting no tax liability: USCC: 60.9; 
Odds on reporting no tax liability: FCC: 2.53; 
Odds on reporting no tax liability: USCC: 1.56; 
Odds ratios: Unadjusted: 1.62; 
Odds ratios: Adjusted: 1.77.

Tax year: 1998; 
Percentage reporting no tax liability: FCC: 71.8; 
Percentage reporting no tax liability: USCC: 61.0; 
Odds on reporting no tax liability: FCC: 2.55; 
Odds on reporting no tax liability: USCC: 1.56; 
Odds ratios: Unadjusted: 1.63; 
Odds ratios: Adjusted: 1.71.

Tax year: 1999; 
Percentage reporting no tax liability: FCC: 72.3; 
Percentage reporting no tax liability: USCC: 61.2; 
Odds on reporting no tax liability: FCC: 2.60; 
Odds on reporting no tax liability: USCC: 1.58; 
Odds ratios: Unadjusted: 1.65; 
Odds ratios: Adjusted: 1.79.

Tax year: 2000; 
Percentage reporting no tax liability: FCC: 73.3; 
Percentage reporting no tax liability: USCC: 63.0; 
Odds on reporting no tax liability: FCC: 2.75; 
Odds on reporting no tax liability: USCC: 1.70; 
Odds ratios: Unadjusted: 1.61; 
Odds ratios: Adjusted: 1.74.

Five-year average; 
Percentage reporting no tax liability: FCC: 71.3; 
Percentage reporting no tax liability: USCC: 61.3; 
Odds on reporting no tax liability: FCC: 2.49; 
Odds on reporting no tax liability: USCC: 1.58; 
Odds ratios: Unadjusted: 1.57; 
Odds ratios: Adjusted: 1.69.

Tax year: 1996; 
Percentage reporting no tax liability: FCC: 88.6; 
Percentage reporting no tax liability: USCC: 94.0; 
Odds on reporting no tax liability: FCC: 7.77; 
Odds on reporting no tax liability: USCC: 15.80; 
Odds ratios: Unadjusted: 0.49; 
Odds ratios: Adjusted: 0.69.

Tax year: 1997; 
Percentage reporting no tax liability: FCC: 88.5; 
Percentage reporting no tax liability: USCC: 93.6; 
Odds on reporting no tax liability: FCC: 7.67; 
Odds on reporting no tax liability: USCC: 14.73; 
Odds ratios: Unadjusted: 0.52; 
Odds ratios: Adjusted: 0.73.

Tax year: 1998; 
Percentage reporting no tax liability: FCC: 89.2; 
Percentage reporting no tax liability: USCC: 93.4; 
Odds on reporting no tax liability: FCC: 8.27; 
Odds on reporting no tax liability: USCC: 14.16; 
Odds ratios: Unadjusted: 0.58; 
Odds ratios: Adjusted: 0.78.

Tax year: 1999; 
Percentage reporting no tax liability: FCC: 90.2; 
Percentage reporting no tax liability: USCC: 93.4; 
Odds on reporting no tax liability: FCC: 9.24; 
Odds on reporting no tax liability: USCC: 14.24; 
Odds ratios: Unadjusted: 0.65; 
Odds ratios: Adjusted: 0.86[A].

Tax year: 2000; 
Percentage reporting no tax liability: FCC: 88.6; 
Percentage reporting no tax liability: USCC: 94.0; 
Odds on reporting no tax liability: FCC: 7.74; 
Odds on reporting no tax liability: USCC: 15.60; 
Odds ratios: Unadjusted: 0.50; 
Odds ratios: Adjusted: 0.66.

Tax year: 5-year average; 
Percentage reporting no tax liability: FCC: 89.0; 
Percentage reporting no tax liability: USCC: 93.7; 
Odds on reporting no tax liability: FCC: 8.10; 
Odds on reporting no tax liability: USCC: 14.88; 
Odds ratios: Unadjusted: 0.54; 
Odds ratios: Adjusted: 0.74. 

Source: GAO analysis of IRS data.

Note: Adjustments to control for age and industry sector involved the 
use of dummy variables to contrast corporations that were less than 3 
years old with other corporations, and to distinguish corporations in 
the manufacturing, wholesale, financial services, nonfinancial 
services, retail, and "other" sectors.

[A] Denotes odds ratios in each year that did not reflect differences 
between FCCs and USSCs. Those not denoted can reasonably, with 95 
percent confidence, be assumed to be due to something other than chance 
or random fluctuations. (The significance of the difference in the 
averaged odds ratios was not tested, since over the 5 years some 
corporations contributed five observations, some contributed four, some 
three, etc.):

[End of table]

Table 22 shows how different large FCCs and USCCs were in each year in 
terms of reporting no tax liability or less than 5 percent of tax 
liability relative to income. The unadjusted odds ratios reveal that 
before controlling for age and industry sector, large FCCs were in 
every year significantly less likely than large USSCs to have reported 
no tax, and in all years except for 1996, they were significantly less 
likely to report less than 5 percent in tax liability. After adjusting 
for age and industry, however, differences between large FCCs' and 
USCCs' likelihood of reporting no tax liability or less than 5 percent 
in tax liability were smaller except for one year (1996). Large FCCs 
were more likely than large USCCs to report no tax liability in 2 of 
the 5 years (1996 and 1998), less likely than large USCCs to report no 
tax liability in 1 year (2000), and no different than large USCCs in 
the other 2 years (1997 and 1999). With respect to reporting tax 
liabilities of less than 5 percent, large FCCs were significantly more 
likely than USCCs to have reported less than 5 percent in tax 
liability, after adjusting for age and industry sector, in 1 year 
(1996), significantly less likely in 2 years (1999 and 2000), and no 
different than USCCs in the other 2 years (1997 and 1998). Most of the 
statistically significant differences between large FCCs and USSCs were 
quite modest, and the odds ratios indicate that the former were not 
very different from the latter in terms of reporting no tax liability 
or of reporting tax liability less than 5 percent of total income.

Table 22: Estimated Percentages and Odds on Reporting No Tax Liability 
and Tax Liability of Less Than 5 Percent of Total Income, between Large 
FCCs and USCCs and Odds Ratios Indicating the Difference between Large 
FCCs and USCCs, before and after Controlling for Age and Industry 
Sector, Tax Years 1996-2000:

Tax year: 1996; 
Percentage reporting no tax liability: FCC: 29.1; 
Percentage reporting no tax liability: USCC: 32.7; 
Odds on reporting no tax liability: FCC: 0.41; 
Odds on reporting no tax liability: USCC: 0.49; 
Odds ratios: Unadjusted: 0.85; 
Odds ratios: Adjusted: 1.15.

Tax year: 1997; 
Percentage reporting no tax liability: FCC: 28.2; 
Percentage reporting no tax liability: USCC: 35.5; 
Odds on reporting no tax liability: FCC: 0.39; 
Odds on reporting no tax liability: USCC: 0.55; 
Odds ratios: Unadjusted: 0.71; 
Odds ratios: Adjusted: 0.97[A].

Tax year: 1998; 
Percentage reporting no tax liability: FCC: 31.3; 
Percentage reporting no tax liability: USCC: 37.8; 
Odds on reporting no tax liability: FCC: 0.46; 
Odds on reporting no tax liability: USCC: 0.61; 
Odds ratios: Unadjusted: 0.75; 
Odds ratios: Adjusted: 1.04.

Tax year: 1999; 
Percentage reporting no tax liability: FCC: 33.8; 
Percentage reporting no tax liability: USCC: 40.9; 
Odds on reporting no tax liability: FCC: 0.51; 
Odds on reporting no tax liability: USCC: 0.69; 
Odds ratios: Unadjusted: 0.74; 
Odds ratios: Adjusted: 1.02[A].

Tax year: 2000; 
Percentage reporting no tax liability: FCC: 37.5; 
Percentage reporting no tax liability: USCC: 45.3; 
Odds on reporting no tax liability: FCC: 0.60; 
Odds on reporting no tax liability: USCC: 0.83; 
Odds ratios: Unadjusted: 0.72; 
Odds ratios: Adjusted: 0.95.

Tax year: 5-year average; 
Percentage reporting no tax liability: FCC: 32.2; 
Percentage reporting no tax liability: USCC: 38.6; 
Odds on reporting no tax liability: FCC: 0.47; 
Odds on reporting no tax liability: USCC: 0.63; 
Odds ratios: Unadjusted: 0.76; 
Odds ratios: Adjusted: 1.02.

Tax year: 1996; 
Percentage reporting no tax liability: FCC: 74.7; 
Percentage reporting no tax liability: USCC: 75.6; 
Odds on reporting no tax liability: FCC: 2.95; 
Odds on reporting no tax liability: USCC: 3.10; 
Odds ratios: Unadjusted: 0.95[A]; 
Odds ratios: Adjusted: 1.14[A].

Tax year: 1997; 
Percentage reporting no tax liability: FCC: 72.0; 
Percentage reporting no tax liability: USCC: 75.5; 
Odds on reporting no tax liability: FCC: 2.57; 
Odds on reporting no tax liability: USCC: 3.08; 
Odds ratios: Unadjusted: 0.84; 
Odds ratios: Adjusted: 1.00[A].

Tax year: 1998; 
Percentage reporting no tax liability: FCC: 74.6; 
Percentage reporting no tax liability: USCC: 77.7; 
Odds on reporting no tax liability: FCC: 2.94; 
Odds on reporting no tax liability: USCC: 3.48; 
Odds ratios: Unadjusted: 0.84; 
Odds ratios: Adjusted: 1.00[A].

Tax year: 1999; 
Percentage reporting no tax liability: FCC: 74.5; 
Percentage reporting no tax liability: USCC: 79.3; 
Odds on reporting no tax liability: FCC: 2.92; 
Odds on reporting no tax liability: USCC: 3.84; 
Odds ratios: Unadjusted: 0.76; 
Odds ratios: Adjusted: 0.92.

Tax year: 2000; 
Percentage reporting no tax liability: FCC: 75.6; 
Percentage reporting no tax liability: USCC: 82.0; 
Odds on reporting no tax liability: FCC: 3.10; 
Odds on reporting no tax liability: USCC: 4.56; 
Odds ratios: Unadjusted: 0.68; 
Odds ratios: Adjusted: 0.81.

Tax year: 5-year average; 
Percentage reporting no tax liability: FCC: 74.3; 
Percentage reporting no tax liability: USCC: 78.1; 
Odds on reporting no tax liability: FCC: 2.90; 
Odds on reporting no tax liability: USCC: 3.56; 
Odds ratios: Unadjusted: 0.81; 
Odds ratios: Adjusted: 0.97. 

Source: GAO analysis of IRS data.

Note: Adjustments to control for age and industry sector involved the 
use of dummy variables to contrast corporations that were less than 3 
years old with other corporations, and to distinguish corporations in 
the manufacturing, wholesale, financial services, nonfinancial 
services, retail, and "other" sectors.

[A] Denotes odds ratios in each year that do not reflect differences 
between FCCs and USSCs. Those not denoted can reasonably, with 95 
percent confidence, be assumed to be due to something other than chance 
or random fluctuations. (The significance of the difference in the 
averaged odds ratios was not tested, since over the 5 years some 
corporations contributed five observations, some contributed four, some 
three, etc.):

[End of table]

[End of section]

Appendix III: GAO Contacts and Staff Acknowledgments:

GAO Contacts:

 James R. White, (202) 512-9110 Ralph T. Block, (415) 904-2150:

Acknowledgments:

 In addition to the individuals above, Jeff Arkin, Susan Baker, Amy 
Friedheim, Shirley Jones, Don Marples, John Mingus, Amy Rosewarne, Sam 
Scrutchins, Doug Sloane, Wendy Turenne, Jennifer Li Wong, and Jim Wozny 
made key contributions to this report.

(450229):

FOOTNOTES

[1] Transfer pricing is the pricing of intercompany transactions that 
affects the distribution of profits and, therefore, taxable income 
among related companies and sometimes across tax jurisdictions.

[2] U.S. General Accounting Office, Tax Administration: Foreign-and 
U.S.-Controlled Corporations That Did Not Pay U.S. Income Taxes, 1989-
95, GAO/GGD-99-39 (Washington, D.C.: Mar. 23, 1999).

[3] GAO/GGD-99-39 and U.S. General Accounting Office, International 
Taxation: Transfer Pricing and Information on Nonpayment of Tax, GAO/
GGD-95-101 (Washington, D.C.: Apr. 13, 1995).

[4] Consistent with our 1999 report, we included the following types of 
corporate tax returns in our analyses: 1120, U.S. Corporation Income 
Tax Return; 1120A, U.S. Corporations Short-Form Income Tax Return; 
1120L, U.S. Life Insurance Company Income Tax Return; 1120PC, U.S. 
Property and Casualty Insurance Company Income Tax Return; 1120REIT, 
U.S. Income Tax Return for Real Estate Investment Trusts; 1120-RIC, 
U.S. Income Tax Return for Regulated Investment Companies; and 1120F, 
U.S. Income Tax Return of a Foreign Corporation. 

[5] Total income is income prior to subtracting deductions for 
allowable expenses.

[6] Gross receipts is one measure of income, but does not include 
subtracting cost of goods sold or adding other types of income, such as 
dividends or interest income.

[7] In all 5 years, 99 percent or more of all corporations were small, 
as we defined them. However, we reported separately on large 
corporations because they make up 93 percent of total assets of all 
corporations.

[8] Logistic regression is an appropriate technique to use when the 
dependent variable is binary, or has two categories, such as whether a 
corporation reported no tax liability versus positive tax liability or 
whether a corporation reported less than 5 percent in tax liability 
versus 5 percent or more in tax liability.

[9] Rounded values are used in this example to show how to simply 
calculate odds ratios.

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