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Journal of Accounting and Economics Vol. 77 No. 2-3 2024

“Just BEAT it” do firms reclassify costs to avoid the base erosion and anti-abuse tax (BEAT) of the TCJA?

Stacie O. Kelley1; Christina Lewellen2; Daniel P. Lynch1; David M. P. Samuel3

1 University of Wisconsin–Madison · 2 North Carolina State University · 3 Singapore Management University

Abstract

This study empirically examines whether firms reclassify related-party payments to avoid the base erosion and anti-abuse tax (BEAT) of the Tax Cuts and Jobs Act (TCJA). We leverage the BEAT filing threshold and use both a difference-in-differences design among U.S. firms and a triple-difference design utilizing the parent company's location to provide evidence that firms reclassify related-party payments to avoid the BEAT. This effect is stronger in firms with greater pre-TCJA income shifting incentives. We estimate a $6 billion aggregate reduction in U.S. taxes for our sample firms in 2018. We also examine the consequences of reclassifying related-party payments and find some evidence of an increase in tax reserves and a reduction in internal information quality for firms that engage in cost reclassification to avoid the BEAT. These findings help explain observed BEAT collection shortfalls, contribute to the current policy debate about international tax reform, and document spillover effects of tax policy.

DOI
10.1016/j.jacceco.2023.101648
Volume
77
Issue
2-3
Pages
101648
Language
en
Sources
openalex crossref bibtex:phds-export.bib

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