The Financing And Taxation Of Us Direct Investment Abroad

A reduction in average tax rates on U.S. investment abroad and a relative shift of U.S. investment toward industrial countries, rather than developing countries, suggests a tougher climate ahead for developing countries that wish to attract foreign direct investment.

Deferral of U.S. taxes on foreign source income is commonly characterized as a subsidy to foreign investment, as reflected in its inclusion among "tax expenditures" and occasional calls for its repeal. This paper analyzes the extent to which tax deferral and other policies inefficiently subsidize U.S. direct investment abroad. Investments are dynamically inefficient if they consistently generate fewer returns to investors than they absorb in new investment funds. From 1982-2010, repatriated earnings from foreign affiliates exceeded net capital investments by $1.1 trillion in 2010 dollars; and from 1950-2010, repatriated earnings and net interest from foreign affiliates exceeded net equity investments and loans by $2.1 trillion in 2010 dollars. By either measure, cash flows received from abroad exceeded 160 percent of net investments, implying that foreign investment over these periods was dynamically efficient.

Emphasizes the difference between foreign fixed investment undertaken by the foreign subsidiary and direct investment of the entire international firm, and the need to use different theoretical frameworks in each case.

USA. Report on the effects on the American economy of the role of USA direct foreign investment and the multinational enterprise - analyzes theoretically and empirically the long term economic implications of export of capital on the economic structure (incl. Income growth, productivity and factor shares), and short term effects on employment, balance of payments, prices, etc. References and statistical tables.

The United States is the largest direct investor abroad and the largest recipient of foreign direct investment in the world. For some Americans, the national gains attributed to investing overseas are offset by such perceived losses as offshoring facilities, displacing U.S. workers, and lowering wages. Some observers believe U.S. firms invest abroad to avoid U.S. labor unions or high U.S. wages, but 74% of the accumulated U.S. foreign direct investment is concentrated in high-income developed countries. In recent years, the share of investment going to developing countries has fallen. Most economists argue that there is no conclusive evidence that direct investment abroad as a whole leads to fewer jobs or lower incomes overall for Americans. Instead, they argue that the majority of jobs lost among U.S. manufacturing firms over the past decade reflect a broad restructuring of U.S. manufacturing industries responding primarily to domestic economic forces. In recent Congresses, Members have introduced a number of measures that would affect U.S. multinational companies in their foreign investment activities. In the 115th Congress, H.R. 685 and S. 247 (Bring Jobs Home Act) would provide certain tax exemptions to U.S. multinational firms to induce them to redirect economic activity from a foreign subsidiary to a domestic U.S. operation. In the 114th Congress, Members also introduced similar measures, including H.R. 297, the Stop Tax Haven Abuse Act of 2015, introduced by Representative Lloyd Doggett on January 13, 2015, and companion measure S. 174, introduced by Senator Sheldon Whitehouse; and H.R. 415, the Stop Corporate Inversions Act of 2015, introduced by Representative Sander Levin on January 20, 2015, and companion measure S. 198, introduced by Senator Richard Durbin. While H.R. 415 and S. 198 are directed at tax inversions, H.R. 297 and S. 174 address a number of tax and financial issues relative to U.S. multinational firms, including the use of foreign tax havens to evade U.S. taxes; money laundering; corporate offshore tax avoidance; and corporate tax inversions.

The analysis presented in this paper shows that u.s. tax policy can have significant effects on u.s. direct investment outflows through various channels. It is stressed that a sensible choice of specification and data in an empirical model entails a rigorous examination of the theoretical underpinnings behind the model. In particular, we emphasize the difference between foreign fixed investment undertaken by the foreign subsidiary and direct investment of the entire international firm, and the need to use different theoretical frameworks in each case. We present estimated equations relating the balance of payments direct investment outflows -- distinguishing between retained Subsidiary earnings and parent transfers -- to various measures of the u.s. net rate of return and the cost of funds. The evidence shows that u.s. tax policy toward domestic investment has an important effect on direct investment outflows by influencing the relative net rate of return between the U.S. and abroad. We estimate that a 16 cent reduction in transfers made by U.S. parents firms occurs for every dollar increase in U.S. domestic investment. In contrast to previous studies, transfers equations fit much better than retained earnings equations for every net return variable used in our estimation. Of the various specifications tested, the transfers equation containing a marginal, forward-looking and corporate-investor net return variable fits best, a result which is consistent with the predictions of our theoretical framework.