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Barriers to Mobility: The Lockout Effect of U.S. Taxation of Worldwide Corporate Profits

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  • Graham, John R.
  • Hanlon, Michelle
  • Shevlin, Terry

Abstract

Using data from a survey of tax executives, we examine the corporate response to the one-time dividends received deduction in the American Jobs Creation Act of 2004. We describe the firms’ reported sources and uses of the cash repatriated and we also examine non-tax costs companies incurred to avoid the repatriation tax prior to the Act. Finally, we examine whether firms would repatriate cash again if a similar Act were to occur in the future. Overall, the evidence is consistent with a substantial lockout effect resulting from the current U.S. policy of taxing the worldwide profits of U.S. multinationals.

Suggested Citation

  • Graham, John R. & Hanlon, Michelle & Shevlin, Terry, 2010. "Barriers to Mobility: The Lockout Effect of U.S. Taxation of Worldwide Corporate Profits," National Tax Journal, National Tax Association;National Tax Journal, vol. 63(4), pages 1111-1144, December.
    • Handle: RePEc:ntj:journl:v:63:y:2010:i:4:p:1111-1144
    DOI: 10.17310/ntj.2010.4S.12
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    Cited by:

    1. Thiess Büttner & Carolin Holzmann, 2019. "Switching from Worldwide to Territorial Taxation: Empirical Evidence of FDI Effects," CESifo Working Paper Series 7462, CESifo.
    2. Jeremiah Harris & William O'Brien, 2022. "Do U.S. firms disguise acquisitions to avoid taxes?," The Financial Review, Eastern Finance Association, vol. 57(1), pages 95-127, February.
    3. Xing, Jing, 2018. "Territorial tax system reform and multinationals' foreign cash holdings: New evidence from Japan," Journal of Corporate Finance, Elsevier, vol. 49(C), pages 252-282.
    4. John R. Graham, 2022. "Presidential Address: Corporate Finance and Reality," Journal of Finance, American Finance Association, vol. 77(4), pages 1975-2049, August.
    5. Beardsley, Erik L. & Robinson, John R. & Wong, Paul A., 2021. "What's my target? Individual analyst forecasts and last-chance earnings management," Journal of Accounting and Economics, Elsevier, vol. 72(1).
    6. Yang, JinHyuk & Kang, Youngho, 2023. "Effects of home country tax reform on FDI inflows to South Korea: A synthetic control method approach," Economics Letters, Elsevier, vol. 225(C).
    7. Harris, Jeremiah & O'Brien, William, 2018. "U.S. worldwide taxation and domestic mergers and acquisitions," Journal of Accounting and Economics, Elsevier, vol. 66(2), pages 419-438.
    8. Sabrina Chi & Shawn X. Huang & Juan Manuel Sanchez, 2017. "CEO Inside Debt Incentives and Corporate Tax Sheltering," Journal of Accounting Research, Wiley Blackwell, vol. 55(4), pages 837-876, September.
    9. Chadwick Curtis & Julio Garin & Saif Mehkari, 2020. "Repatriation Taxes," Review of Economic Dynamics, Elsevier for the Society for Economic Dynamics, vol. 36, pages 293-313, April.
    10. 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.).
    11. Kevin S. Markle & Douglas A. Shackelford, 2011. "Cross-Country Comparisons of Corporate Income Taxes," NBER Working Papers 16839, National Bureau of Economic Research, Inc.
    12. 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.
    13. Dhammika Dharmapala, 2018. "The Consequences of the TCJA's International Provisions: Lessons from Existing Research," CESifo Working Paper Series 7249, CESifo.
    14. Dong, Qi Flora & Cao, Yiting & Zhao, Xin & Deshmukh, Ashutosh, 2019. "Responses of US multinational firms to a temporary repatriation tax holiday: A literature review and synthesis," Journal of Accounting Literature, Elsevier, vol. 43(C), pages 108-123.
    15. Michalis Nikiforos & Gennaro Zezza, 2018. "'America First,' Fiscal Policy, and Financial Stability," Economics Strategic Analysis Archive sa_apr_18, Levy Economics Institute.
    16. Michelle Hanlon & Jeffrey L. Hoopes & Joel Slemrod, 2019. "Tax Reform Made Me Do It!," Tax Policy and the Economy, University of Chicago Press, vol. 33(1), pages 33-80.
    17. Kevin S Markle, 2012. "A Comparison of the Tax-motivated Income Shifting of Multinationals in Territorial and Worldwide Countries," Working Papers 1206, Oxford University Centre for Business Taxation.
    18. Urooj Khan & Suresh Nallareddy & Ethan Rouen, 2020. "The Role of Taxes in the Disconnect Between Corporate Performance and Economic Growth," Management Science, INFORMS, vol. 66(11), pages 5427-5447, November.
    19. John R. Graham & Michelle Hanlon & Terry Shevlin, 2011. "Real Effects of Accounting Rules: Evidence from Multinational Firms’ Investment Location and Profit Repatriation Decisions," Journal of Accounting Research, Wiley Blackwell, vol. 49(1), pages 137-185, March.
    20. Saskia Kohlhase & Jochen Pierk, 2020. "The effect of a worldwide tax system on tax management of foreign subsidiaries," Journal of International Business Studies, Palgrave Macmillan;Academy of International Business, vol. 51(8), pages 1312-1330, October.

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