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Bringing It Home: A Study of the Incentives Surrounding the Repatriation of Foreign Earnings Under the American Jobs Creation Act of 2004

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  • JENNIFER BLOUIN
  • LINDA KRULL
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    Abstract

    ABSTRACT The American Jobs Creation Act of 2004 (the Act) creates a temporary tax holiday that effectively reduces the U.S. tax rate on repatriations from foreign subsidiaries from 35% to 5.25%. Firms receive the reduced tax rate by electing to take an 85% dividends received deduction on repatriations in 2004 or 2005. This paper investigates the characteristics of firms that repatriate under the Act and how they use the repatriated funds. We find that firms that repatriate under the Act have lower investment opportunities and higher free cash flows than nonrepatriating firms. Further, we find that repatriating firms increase share repurchases during 2005 by approximately $60 billion more than nonrepatriating firms, an amount that cannot be explained by differences in earnings between the two groups of firms. This increase represents about 20% of the $291.6 billion repatriated by our sample firms under the Act. Copyright (c), University of Chicago on behalf of the Accounting Research Center, 2009.

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    Article provided by Wiley Blackwell in its journal Journal of Accounting Research.

    Volume (Year): 47 (2009)
    Issue (Month): 4 (09)
    Pages: 1027-1059

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    Handle: RePEc:bla:joares:v:47:y:2009:i:4:p:1027-1059

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    Cited by:
    1. Douglas Shackelford & Joel Slemrod & James Sallee, 2011. "Financial reporting, tax, and real decisions: toward a unifying framework," International Tax and Public Finance, Springer, vol. 18(4), pages 461-494, August.
    2. Anken, F. & Beasley, J.E., 2012. "Corporate structure optimisation for multinational companies," Omega, Elsevier, vol. 40(2), pages 230-243, April.
    3. Graham, John R. & Raedy, Jana S. & Shackelford, Douglas A., 2012. "Research in accounting for income taxes," Journal of Accounting and Economics, Elsevier, vol. 53(1), pages 412-434.
    4. Hanlon, Michelle & Heitzman, Shane, 2010. "A review of tax research," Journal of Accounting and Economics, Elsevier, vol. 50(2-3), pages 127-178, December.
    5. Michael Brei, 2013. "Offshore financial centers in the Caribbean: An overview," EconomiX Working Papers 2013-40, University of Paris West - Nanterre la Défense, EconomiX.
    6. Jesse Edgerton, 2013. "Four facts about dividend payouts and the 2003 tax cut," International Tax and Public Finance, Springer, vol. 20(5), pages 769-784, October.
    7. Lee Pinkowitz & René M. Stulz & Rohan Williamson, 2012. "Multinationals and the High Cash Holdings Puzzle," NBER Working Papers 18120, National Bureau of Economic Research, Inc.
    8. Dyreng, Scott D. & Lindsey, Bradley P. & Thornock, Jacob R., 2013. "Exploring the role Delaware plays as a domestic tax haven," Journal of Financial Economics, Elsevier, vol. 108(3), pages 751-772.

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