Citi's Rai on Repatriation
Citi Research published, "U.S. repatriation tax - myths and possibilities." Author Vikrma Rai writes, "Repatriation tax or taxing the U.S. multinational corporate earnings stranded offshore is a priority on the new administration's agenda whether to finance an ambitious domestic infrastructure program or to bring down the cost of tax reform. We discuss the myths and possibilities of a U.S. repatriation tax program.... It is widely estimated that U.S. MNCs have approximately $2.5 trillion in profits stashed abroad though we could analyze and account for less than $1.5 trillion." The piece tells us, "Repatriation of earnings is unlikely to affect yields through the avenue of fund flows. As discussed above, most of the US corporate earnings that are currently held outside US jurisdiction are already in USD-denominated assets. Therefore, contrary to popular belief, a repatriation program will not result in inflows into US based money funds or bond funds. The other potential mechanism by which repatriation could greatly affect yields is through liquidations of those USD-denominated assets. But our expectations for this too are that it is unlikely to occur in any significant magnitude.... In 2004, the dividends paid by foreign subsidiaries to US companies were taxed at just 5.25%. Although there were restrictions in place that said any money repatriated under the lower rate was to be used for "funding of worker hiring and training, infrastructure, research and development, capital investments, or the financial stabilization of the corporation for the purposes of job retention and creation," corporations back then found ways around this."
