U.S. Multinational Companies’ Payout and Investment Decisions in Response to International Tax Provisions of the Tax Cuts and Jobs Act of 2017

Abstract

The Tax Cuts and Jobs Act of 2017 (TCJA) dramatically changed U.S. taxation of foreign earnings for U.S. multinational companies (MNCs). Specifically, the TCJA required taxation of existing unremitted foreign earnings through a deemed repatriation and effectively eliminated future repatriation taxes through a 100 percent dividends received deduction. Additionally, the bill introduced the global intangible low-taxed income (GILTI) regime. We examine MNCs’ responses to the TCJA and find that spending and investment behavior depends on liquidity, investment opportunities, and borrowing costs. Domestic capital expenditures and share repurchases increased for MNCs with low domestic liquidity and high domestic investment opportunities. In contrast, MNCs with low domestic liquidity (high cost of debt) and low domestic investment opportunities increased dividends (decreased debt). Finally, we find that MNCs with high foreign cash and most vulnerable to the GILTI regime increased their foreign but not domestic capital expenditures—a potential unintended consequence.