U.S. Cash Repatriation Plunges 50%, Defying Trump's Tax Forecast

(Bloomberg) -- The amount of offshore cash corporations are bringing back to the U.S. dropped sharply for a second straight quarter, falling short of the trillions of dollars President Donald Trump had promised would result from his tax overhaul.

Companies repatriated $92.7 billion in the July-September period, the lowest amount this year and down almost 50 percent from the previous quarter, according to data released Wednesday by the Commerce Department. U.S. corporations repatriated $294.9 billion in the first three months of 2018 and $183.7 billion in the second quarter.

The latest quarter’s total compares with $55.1 billion from the same period a year earlier -- before the tax law took effect. The tax overhaul signed into law by Trump last December gave companies incentives to bring money back to the U.S. by lowering the tax rate on repatriated profits.

The new rules set a one-time rate of 15.5 percent on cash and 8 percent on non-cash or illiquid assets. Companies pay the "deemed" tax whether or not they actually bring the assets back. Previously, firms had to pay the old 35 percent corporate rate, but only if they brought the money back to the U.S.

Trump has said, without specifying his source, that he expects more than $4 trillion to return to the U.S., which will help to create jobs and more investment.

The repatriation figures were part of a quarterly report on the current-account deficit, which widened to $124.8 billion in the July-September period from $101.2 billion. The gap is considered the broadest measure of international trade because it includes income payments and government transfers.

The amount of cash accumulated offshore is probably closer to $2.5 trillion than $4 trillion, according to Gordon Gray, the director of fiscal policy at American Action Forum. Gray said he thought the high repatriation amounts in the first two quarters aren’t likely to be repeated -- but the levels going forward will ultimately still be greater than before the tax law.

Even though companies are less restricted in moving their offshore profits under the U.S. tax overhaul, corporations, in aggregate, are choosing to keep earnings in their foreign subsidiaries, a team of Morgan Stanley analysts led by Todd Castagno said in a note earlier this month.

“The sharp drop and trend trajectory is surprising -- and may require analysts and investors to rethink their near-term capital deployment and return expectations,” the note said.

It’s still unclear whether any money that is being repatriated is being used for capital expenditures, according to Kyle Pomerleau, an economist at the right-leaning Tax Foundation.

“A company could get an extra couple of billion from overseas, but that doesn’t change their willingness to invest the cash,” Pomerleau said. “Most analysts -- myself included -- assumed that repatriation would provide no boost in investment to begin with.”

The new repatriation tax has been a source of pain for some multinationals that overpaid what they owe -- a common tactic companies use to avoid penalties for paying too little. Firms, which can opt to pay the levy over eight years, had been expecting a refund for the excess amounts.

The Internal Revenue Service said in August that it won’t rebate any such overpayments and would only credit them to future repatriation taxes, not apply them toward other taxes due, such as corporate income. The House Rules Committee is considering a tax bill Wednesday that would include a technical fix to the law clarifying that corporations can get refunds for the overpayments.

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