I find that foreign multinational firms engage in tax-motivated income shifting out of the United States. The analysis uses novel data on foreign-owned U.S. subsidiaries as well as variation in foreign countries’ tax rates and controlled foreign corporation rules. Foreign multinational firms primarily rely on tax-motivated transfer pricing to shift income out of the United States, and the aggregate amount of shifted income is modest. When foreign tax policy changes inhibit income shifting, foreign-owned U.S. subsidiaries’ investment and employment fall. The results indicate that the U.S. economy has limited exposure to tax policies set abroad through foreign direct investment in the United States.

An abstract is not available for this content so a preview has been provided. Please use the Get access link above for information on how to access this content.

The Tax Cuts and Jobs Act unlocked as much as $1.7 trillion of U.S. multinationals’ foreign cash. We examine the real and financial response to this liquidity shock and find that firms did not increase capital expenditures, employment, R&D, or M&A, regardless of financial constraints. On the financial side, firms paid out only about one-third of the new liquidity to shareholders and retained half as cash. This high retention was not associated with poor governance. The high propensity to retain the liquidity shock as cash, even among well-governed firms with limited financial constraints, is difficult to reconcile with existing theory.

We estimate a dynamic model, featuring agency conflicts and a stochastic tax reform arrival, to evaluate how the change from a worldwide to territorial tax system, enacted under the Tax Cuts and Jobs Act (TCJA), affects foreign investment. Although a worldwide system imposes a higher tax liability on foreign income, we show it encourages excess foreign investment by depressing the opportunity cost of capital. In our estimated model, the TCJA reduces foreign investment by 15.6% on average, with larger declines for services firms and firms with lesser agency conflicts. The reform probability, which we estimate in the model, significantly affects firms’ investment and cash holdings.