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Do Repatriation Taxes Matter? Evidence from the Tax Returns of U.S. Multinationals

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Author Info
Rosanne Altshuler () (Rutgers University, Department of Economics)
T. Scott Newlon (U.S. Treasury Department)
William Randolph (U.S. Dept. of Treasury)

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Abstract

An open question in the literature on the taxation of multinational corporations is whether repatriation taxes influence whether the profits of foreign subsidiaries are repatriated or reinvested abroad. Theoretical models suggest that dividend remittances should not be influenced by repatriation taxes. The results of recent empirical work indicate that dividend remittances are sensitive to repatriation taxes. This paper investigates whether the empirical evidence can be reconciled with the theoretical results by recognizing that repatriation taxes on dividends may vary over time and provide firms with an incentive to time repatriations so that they occur in years when repatriation tax rates are relatively low. We use information about cross- country differences in tax rates to separately estimate the influence of permanent tax changes, as would occur due to changes in statutory tax rates, and transitory tax changes on dividend repatriations. Our data contains U.S. tax return information for a large sample of U.S. corporations and their foreign subsidiaries. We find that the permanent tax price effect is significantly different from the transitory price effect and is not significantly different from zero, while the transitory tax price effect is negative and significant. This suggests that repatriation taxes do affect dividend repatriation behavior but only to the extent that they vary over time. Previous empirical work has apparently measured the effect of timing behavior.

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Publisher Info
Paper provided by Rutgers University, Department of Economics in its series Departmental Working Papers with number 199405.

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Date of creation: 02 Oct 1996
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Handle: RePEc:rut:rutres:199405

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Related research
Keywords: dividend repatriation; foreign tax credit; international taxation; multinational corporations; repatriation taxes;

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Find related papers by JEL classification:
H25 - Public Economics - - Taxation, Subsidies, and Revenue - - - Business Taxes and Subsidies
H32 - Public Economics - - Fiscal Policies and Behavior of Economic Agents - - - Firm
H87 - Public Economics - - Miscellaneous Issues - - - International Fiscal Issues; International Public Goods

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  1. Altshuler, R. & Fulghieri, P., 1990. "Incentive Effects Of Foreign Tax Credits On Multinationals," Discussion Papers 1990_11, Columbia University, Department of Economics.
  2. Bradford, David F., 1981. "The incidence and allocation effects of a tax on corporate distributions," Journal of Public Economics, Elsevier, vol. 15(1), pages 1-22, February. [Downloadable!] (restricted)
    Other versions:
  3. Auerbach, Alan J, 1979. "Wealth Maximization and the Cost of Capital," The Quarterly Journal of Economics, MIT Press, vol. 93(3), pages 433-46, August. [Downloadable!] (restricted)
    Other versions:
  4. Leechor, Chad & Mintz, Jack, 1993. "On the taxation of multinational corporate investment when the deferral method is used by the capital exporting country," Journal of Public Economics, Elsevier, vol. 51(1), pages 75-96, May. [Downloadable!] (restricted)
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(explanations, Please report citation or reference errors to , or , if you are the registered author of the cited work, log in to your RePEc Author Service profile, click on "citations" and make appropriate adjustments.)

  1. Bruce A. Blonigen & Ronald B. Davies, 2001. "Do Bilateral Tax Treaties Promote Foreign Investment?," University of Oregon Economics Department Working Papers 2001-12, University of Oregon Economics Department, revised 01 Jun 2001. [Downloadable!]
  2. Rosanne Altshuler, 2000. "Recent Developments in the Debate on Deferral," Departmental Working Papers 200013, Rutgers University, Department of Economics. [Downloadable!]
  3. James R. Hines, Jr., 1996. "Tax Policy and the Activities of Multinational Corporations," NBER Working Papers 5589, National Bureau of Economic Research, Inc. [Downloadable!] (restricted)
  4. Julie H. Collins & John R. M. Hand & Douglas A. Shackelford, 2000. "Valuing Deferral: The Effect of Permanently Reinvested Foreign Earnings on Stock Prices," NBER Chapters, in: International Taxation and Multinational Activity, pages 143-172 National Bureau of Economic Research, Inc. [Downloadable!]
  5. Bruce Blonigen & Ronald Davies, 2004. "The Effects of Bilateral Tax Treaties on U.S. FDI Activity," Asia-Pacific Financial Markets, Springer, vol. 11(5), pages 601-622, September. [Downloadable!] (restricted)
    Other versions:
  6. James R. Hines, Jr., 1997. "Taxed Avoidance: American Participation in Unsanctioned International Boycotts," NBER Working Papers 6116, National Bureau of Economic Research, Inc. [Downloadable!] (restricted)
  7. Mihir A. Desai & James R. Hines Jr., 2000. "The Uneasy Marriage of Export Incentives and the Income Tax," NBER Working Papers 8009, National Bureau of Economic Research, Inc. [Downloadable!] (restricted)
    Other versions:
  8. Ronald Davies, 2004. "Tax Treaties and Foreign Direct Investment: Potential versus Performance," Asia-Pacific Financial Markets, Springer, vol. 11(6), pages 775-802, November. [Downloadable!] (restricted)
    Other versions:
  9. Rosanne Altshuler & Harry Grubert, 1998. "Multinational Financial Policy and the Cost of Capital: The Many Roads Home," Departmental Working Papers 199807, Rutgers University, Department of Economics. [Downloadable!]
  10. Ronald B. Davies, 1999. "The OECD Model Tax Treaty: Tax Competition and Two-Way Capital," University of Oregon Economics Department Working Papers 2002-7, University of Oregon Economics Department, revised 01 Jan 2002. [Downloadable!]
  11. Mihir A. Desai & James R. Hines Jr., 2004. "Market Reactions to Export Subsidies," NBER Working Papers 10233, National Bureau of Economic Research, Inc. [Downloadable!] (restricted)
    Other versions:
  12. Ronald B. Davies, 2003. "Tax Treaties, Renegotiations, and Foreign Direct Investment," University of Oregon Economics Department Working Papers 2003-14, University of Oregon Economics Department, revised 10 Jun 2003. [Downloadable!]
    Other versions:
  13. Bruce A. Blonigen & Ronald B. Davies, 2002. "Do Bilateral Tax Treaties Promote Foreign Direct Investment?," NBER Working Papers 8834, National Bureau of Economic Research, Inc. [Downloadable!] (restricted)
  14. Darrel Cohen & Kevin A. Hassett & R. Glenn Hubbard, 1999. "Inflation and the User Cost of Capital: Does Inflation Still Matter?," NBER Working Papers 6046, National Bureau of Economic Research, Inc. [Downloadable!] (restricted)
    Other versions:
  15. Roger H. Gordon & James R. Hines Jr., 2002. "International Taxation," NBER Working Papers 8854, National Bureau of Economic Research, Inc. [Downloadable!] (restricted)
    Other versions:
    • Gordon, Roger H. & Hines, James Jr, 2002. "International taxation," Handbook of Public Economics, in: A. J. Auerbach & M. Feldstein (ed.), Handbook of Public Economics, edition 1, volume 4, chapter 28, pages 1935-1995 Elsevier. [Downloadable!] (restricted)
  16. Rosanne Altshuler & Harry Grubert, 1996. "Balance Sheets, Multinational Financial Policy, and the Cost of Capital at Home and Abroad," NBER Working Papers 5810, National Bureau of Economic Research, Inc. [Downloadable!] (restricted)
  17. Rosanne Altshuler & Harry Grubert, 2002. "Repatriation Taxes, Repatriation Strategies and Multinational Financial Policy," Departmental Working Papers 200009, Rutgers University, Department of Economics. [Downloadable!]
    Other versions:
  18. James R. Hines Jr., 2004. "Do Tax Havens Flourish?," NBER Working Papers 10936, National Bureau of Economic Research, Inc. [Downloadable!] (restricted)
    Other versions:
    • James R. Hines Jr., 2005. "Do Tax Havens Flourish?," NBER Chapters, in: Tax Policy and the Economy, Volume 19, pages 65-100 National Bureau of Economic Research, Inc. [Downloadable!]
  19. Mihir A. Desai & C. Fritz Foley & James R. Hines Jr., 2001. "Repatriation Taxes and Dividend Distortions," NBER Working Papers 8507, National Bureau of Economic Research, Inc. [Downloadable!] (restricted)
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