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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

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.

Suggested Citation

  • Jennifer Blouin & Linda Krull, 2009. "Bringing It Home: A Study of the Incentives Surrounding the Repatriation of Foreign Earnings Under the American Jobs Creation Act of 2004," Journal of Accounting Research, Wiley Blackwell, vol. 47(4), pages 1027-1059, September.
  • 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;International Institute of Public Finance, vol. 18(4), pages 461-494, August.
    2. Hanlon, Michelle & Lester, Rebecca & Verdi, Rodrigo, 2015. "The effect of repatriation tax costs on U.S. multinational investment," Journal of Financial Economics, Elsevier, vol. 116(1), pages 179-196.
    3. Koethenbuerger, Marko & Stimmelmayr, Michael, 2016. "Taxing multinationals in the presence of internal capital markets," Journal of Public Economics, Elsevier, vol. 138(C), pages 58-71.
    4. Jaafar, Aziz & Thornton, John, 2015. "Tax Havens and Effective Tax Rates: An Analysis of Private versus Public European Firms," The International Journal of Accounting, Elsevier, vol. 50(4), pages 435-457.
    5. Anken, F. & Beasley, J.E., 2012. "Corporate structure optimisation for multinational companies," Omega, Elsevier, vol. 40(2), pages 230-243, April.
    6. Jesse Edgerton, 2013. "Four facts about dividend payouts and the 2003 tax cut," International Tax and Public Finance, Springer;International Institute of Public Finance, vol. 20(5), pages 769-784, October.
    7. 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.
    8. Pinkowitz, Lee & Stulz, Rene M. & Williamson, Rohan, 2012. "Multinationals and the High Cash Holdings Puzzle," Working Paper Series 2012-10, Ohio State University, Charles A. Dice Center for Research in Financial Economics.
    9. repec:spr:reaccs:v:22:y:2017:i:2:d:10.1007_s11142-017-9390-6 is not listed on IDEAS
    10. Beyer, Brooke & Downes, Jimmy & Rapley, Eric T., 2017. "Internal capital market inefficiencies, shareholder payout, and abnormal leverage," Journal of Corporate Finance, Elsevier, vol. 43(C), pages 39-57.
    11. repec:eee:jfinec:v:124:y:2017:i:3:p:441-463 is not listed on IDEAS
    12. Floyd, Eric & Li, Nan & Skinner, Douglas J., 2015. "Payout policy through the financial crisis: The growth of repurchases and the resilience of dividends," Journal of Financial Economics, Elsevier, vol. 118(2), pages 299-316.
    13. Hanlon, Michelle & Heitzman, Shane, 2010. "A review of tax research," Journal of Accounting and Economics, Elsevier, vol. 50(2-3), pages 127-178, December.
    14. Dobridge, Christine L., 2016. "Fiscal Stimulus and Firms: A Tale of Two Recessions," Finance and Economics Discussion Series 2016-13, Board of Governors of the Federal Reserve System (U.S.).
    15. Dane M. Christensen & Dan S. Dhaliwal & Steven Boivie & Scott D. Graffin, 2015. "Top management conservatism and corporate risk strategies: Evidence from managers' personal political orientation and corporate tax avoidance," Strategic Management Journal, Wiley Blackwell, vol. 36(12), pages 1918-1938, December.
    16. Harendt, Christoph & Dreßler, Daniel & Overesch, Michael, 2016. "The Impact of Tax Treaties and Repatriation Taxes on FDI Revisited," Annual Conference 2016 (Augsburg): Demographic Change 145588, Verein für Socialpolitik / German Economic Association.
    17. repec:eee:corfin:v:44:y:2017:i:c:p:126-148 is not listed on IDEAS
    18. 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.
    19. repec:kap:rqfnac:v:50:y:2018:i:2:d:10.1007_s11156-017-0640-2 is not listed on IDEAS
    20. Hasegawa, Makoto & Kiyota, Kozo, 2017. "The effect of moving to a territorial tax system on profit repatriation: Evidence from Japan," Journal of Public Economics, Elsevier, vol. 153(C), pages 92-110.
    21. Liu, Harrison & Swanson, Edward P., 2016. "Is price support a motive for increasing share repurchases?," Journal of Corporate Finance, Elsevier, vol. 38(C), pages 77-91.
    22. Michael Brei, 2013. "Offshore financial centers in the Caribbean: An overview," EconomiX Working Papers 2013-40, University of Paris Nanterre, EconomiX.
    23. De Simone, Lisa & Piotroski, Joseph D. & Tomy, Rimmy E., 2017. "Repatriation Taxes and Foreign Cash Holdings: The Impact of Anticipated Tax Policy," Research Papers 3507, Stanford University, Graduate School of Business.
    24. repec:eee:jfinec:v:125:y:2017:i:2:p:344-368 is not listed on IDEAS
    25. Aaron Flaaen, 2017. "The Role of Transfer Prices in Profit-Shifting by U.S. Multinational Firms : Evidence from the 2004 Homeland Investment Act," Finance and Economics Discussion Series 2017-055, Board of Governors of the Federal Reserve System (U.S.).

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