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Positive Externality of the American Jobs Creation Act of 2004

Published online by Cambridge University Press:  13 November 2019

Xiaoli Hu ,
Oliver Zhen Li ,
Yuehua Li  and
Sha Pei
Xiaoli Hu
Affiliation:
Hu, [email protected], City University of Hong Kong Department of Accountancy
Oliver Zhen Li*
Affiliation:
Li, [email protected], Shanghai Lixin University of Accounting and Finance School of Accounting and National University of Singapore Department of Accounting
Yuehua Li
Affiliation:
Li, [email protected], Shanghai University of Finance and Economics School of Accountancy
Sha Pei
Affiliation:
Pei, [email protected], Shanghai Lixin University of Accounting and Finance School of Accounting
*
Li (corresponding author), [email protected]
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Abstract

U.S. multinational enterprises repatriated over $300 billion under the 2004 tax holiday. The repatriated funds can improve debt financing environment of nonrepatriating firms, especially those that are financially constrained. We document that such an externality of the tax holiday increases debt financing and consequently investments for financially constrained nonrepatriating firms relative to less constrained nonrepatriating firms. Using private loan market data, we further confirm a link from repatriated funds to increased debt financing for financially constrained nonrepatriating firms. Overall, the 2004 tax holiday appears to have benefited the U.S. economy through its positive externality on the debt market.

Type
Research Article
Information
Journal of Financial and Quantitative Analysis , Volume 56 , Issue 2 , March 2021 , pp. 607 - 646
Copyright
© Michael G. Foster School of Business, University of Washington 2019

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Footnotes

We thank Michelle Hanlon (the referee) and Paul Malatesta (the editor) for comments and suggestions. Oliver Zhen Li acknowledges support from the National Natural Science Foundation of China (Grant #: 71972135) and Musim Mas Professorship. All errors are ours.

References

Albring, S. M.; Dzuranin, A. C.; and Mills, L. F.. “Tax Savings on Repatriations of the Foreign Earnings Under the Jobs Act.” Tax Notes, 108 (2005), 655–669.Google Scholar
Albring, S. M.; Mills, L. F.; and Newberry, K. J.. “Do Debt Constraints Influence Firms’ Sensitivity to A Temporary Tax Holiday on Repatriations?” Journal of the American Taxation Association, 33 (2011), 1–27.Google Scholar
Altman, E. I. “Predicting Financial Distress of Companies: Revisiting the Z-Score and ZETA Models.” Working Paper, New York University (2000).Google Scholar
Altshuler, R., and Grubert, H.. “Repatriation Taxes, Repatriation Strategies and Multinational Financial Policy.” Journal of Public Economics, 87 (2002), 73–107.Google Scholar
Altshuler, R., and Newlon, T. S.. “The Effects of U.S. Tax Policy on the Income Repatriation Patterns of U.S. Multinational Corporations.” In Studies in International Taxation, Giovannini, A., Hubbard, R. G., and Slemrod, J., eds. Chicago, IL: University of Chicago Press (1993), 77–116.Google Scholar
Asquith, P.; Gertner, R.; and Scharfstein, D.. “Anatomy of Financial Distress: An Examination of Junk-Bond Issuers.” Quarterly Journal of Economics, 109 (1994), 625–658.Google Scholar
Benmelech, E.; Dlugosz, J.; and Ivashina, V.. “Securitization without Adverse Selection: The Case of CLOs.” Journal of Financial Economics, 106 (2012), 91–113.Google Scholar
Bharath, S. T.; Dahiya, S.; Saunders, A.; and Srinivasan, A.. “Lending Relationships and Loan Contract Terms.” Review of Financial Studies, 24 (2011), 1141–1203.Google Scholar
Blouin, J., and Krull, L.. “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, 47 (2009), 1027–1059.Google Scholar
Brennan, T. J. “Where the Money Really Went: A New Understanding of the AJCA Tax Holiday.” Working Paper, Northwestern University (2014).Google Scholar
Clemons, R., and Kinney, M. R.. “An Analysis of the Tax Holiday for Repatriation under the Jobs Act.” Tax Notes, 120 (2008), 759–768.Google Scholar
De Waegenaere, A., and Sansing, R. C.. “Taxation of International Investment and Accounting Valuation.” Contemporary Accounting Research, 25 (2008), 1045–1066.Google Scholar
DeAngelo, H., and DeAngelo, L.. “Dividend Policy and Financial Distress: An Empirical Investigation of Troubled NYSE Firms.” Journal of Finance, 45 (1990), 415–1431.Google Scholar
Department of the Treasury, “Internal Revenue Service.” Internal Revenue Cumulative Bulletin, January–June (2005), 477–480.Google Scholar
Desai, M. A.; Foley, C. F.; and Hines, J. R.. “Repatriation Taxes and Dividend Distortions.” National Tax Journal, 54 (2001), 829–851.Google Scholar
Desai, M. A., and Hines, J. R. Jr. “Expectations and Expatriations: Tracing the Causes and Consequences of Corporate Inversions.” National Tax Journal, 55 (2002), 409–440.Google Scholar
Dharmapala, D.; Foley, C. F.; and Forbes, K. J.. “Watch What I Do, Not What I Say: The Unintended Consequences of the Homeland Investment Act.” Journal of Finance, 66 (2011), 753–787.Google Scholar
Edwards, A.; Kravet, T.; and Wilson, R.. “Trapped Cash and the Profitability of Foreign Acquisitions.” Contemporary Accounting Research, 33 (2016), 44–77.Google Scholar
Erel, I.; Julio, B.; Kim, W.; and Weisbach, M. S.. “Macroeconomic Conditions and Capital Raising.” Review of Financial Studies, 25 (2012), 341–376.Google Scholar
Faulkender, M.; Hankins, K.; and Petersen, M.. “Understanding the Rise in Corporate Cash: Precautionary Savings or Foreign Taxes.” Review of Financial Studies, hhz003 (2019).Google Scholar
Faulkender, M., and Petersen, M.. “Investment and Capital Constraints: Repatriations under the American Jobs Creation Act.” Review of Financial Studies, 25 (2012), 3352–3388.Google Scholar
Foley, C. F.; Hartzell, J. C.; Titman, S.; and Twite, G.. “Why Do Firms Hold So Much Cash? A Tax-Based Explanation.” Journal of Financial Economics, 86 (2007), 579–607.Google Scholar
Graham, J. R.; Hanlon, M.; and Shevlin, T.. “Barriers to Mobility: The Lockout Effect of U.S. Taxation of Worldwide Corporate Profits.” National Tax Journal, 63 (2010), 1111–1144.Google Scholar
Grubert, H. “Taxes and the Division of Foreign Operating Income among Royalties, Interest, Dividends and Retained Earnings.” Journal of Public Economics, 68 (1998), 269–290.Google Scholar
Hadlock, C. J., and Pierce, J. R.. “New Evidence on Measuring Financial Constraints: Moving Beyond the KZ Index.” Review of Financial Studies, 23 (2010), 1909–1940.Google Scholar
Hanlon, M.; Lester, R.; and Verdi, R.. “The Effect of Repatriation Tax Costs on U.S. Multinational Investment.” Journal of Financial Economics, 116 (2015), 179–196.Google Scholar
Hartman, D. G. “Tax Policy and Foreign Direct Investment.” Journal of Public Economics, 26 (1985), 107–121.Google Scholar
Hoberg, G., and Maksimovic, V.. “Redefining Financial Constraints: A Text-Based Analysis.” Review of Financial Studies, 28 (2014), 1312–1352.Google Scholar
Jensen, M. C. “Agency Costs of Free Cash Flow, Corporate Finance, and Takeovers.” American Economic Review, 76 (1986), 323–329.Google Scholar
Joint Committee on Taxation, (2016). Response to requests from U.S. House of Representatives. Available at: https://waysandmeans.house.gov/wp-content/uploads/2016/09/20160831-Barthold-Letter-to-BradyNeal.pdf [no longer active].Google Scholar
Lemmon, M., and Roberts, M. R.. “The Response of Corporate Financing and Investment to Changes in the Supply of Credit.” Journal of Financial and Quantitative Analysis, 45 (2010), 555–587.Google Scholar
Lester, R. “Made in the U.S.A.? A Study of Firm Responses to Domestic Production Incentives.” Journal of Accounting Research, 2019.Google Scholar
Lester, R., and Rector, R.. “Which Companies Use the Domestic Production Activities Deduction?” Tax Notes, 152 (2016), 1269–1292.Google Scholar
Lown, C. S.; Morgan, D. P.; and Rohatgi, S.. “Listening to Loan Officers: The Impact of Commercial Credit Standards on Lending and Output.” Economic Policy Review, 6 (2000), 1–16.Google Scholar
Mider, Z. “Tax Inversion. Bloomberg QuickTake.” (2017). Available at: http://www.bloombergview.com/quicktake/tax-inversion.Google Scholar
Moody. “Corporate Cash Pile Declines 9.5% to $1.8 Trillion.” 2018. Available at: https://www.moodys.com/researchdocumentcontentpage.aspx?docid=PBC_1150711.Google Scholar
Oler, M.; Shevlin, T.; and Wilson, R.. “Examining Investor Expectations Concerning Tax Savings on the Repatriations of Foreign Earnings under the American Jobs Creation Act of 2004.” Journal of the American Taxation Association, 29 (2007), 25–55.Google Scholar
Permanent Subcommittee on Investigations. “Repatriating Offshore Funds: 2004 Tax Windfall for Select Multinationals.” United States Senate Majority Staff Report (2011).Google Scholar
Redmiles, M. “The One-Time Received Dividend Deduction.” Statistics of Income, SOI Bulletin, 27 (2008), 102–114.Google Scholar
Seida, J. A., and Wempe, W. F.. “Effective Tax Rate Changes and Earnings Stripping Following Corporate Inversion.” National Tax Journal, 57 (2004), 805–828.Google Scholar
Standard and Poor’s Ratings Services. “Cash Update: Cheap Debt Fuels Record High Cash Growth.” (2014).Google Scholar
Wang, Y., and Xia, H.. “Do Lenders Still Monitor When They Can Securitize Loans?” Review of Financial Studies, 27 (2014), 2354–2391.Google Scholar