Article | National Tax Journal

Tax Policy and the Efficiency of U.S. Direct Investment Abroad

by Mihir A. Desai, C. Fritz Foley and James R. Hines Jr.

Abstract

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 to 2010, repatriated earnings from foreign affiliates exceeded net capital investments by $1.1 trillion in 2010 dollars; and from 1950 to 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% of net investments, implying that foreign investment over these periods was dynamically efficient.

Keywords: Policy; Taxation; Performance Efficiency; Foreign Direct Investment; Investment Funds; Investment Return; Business Earnings; Equity; Financing and Loans; Cash Flow; Capital; United States;

Citation:

Desai, Mihir A., C. Fritz Foley, and James R. Hines Jr. "Tax Policy and the Efficiency of U.S. Direct Investment Abroad." National Tax Journal 64, no. 4 (December 2011): 1055–1082.