The business cycle and the deduction for foreign derived intangible income : a historical perspective Tim Dowd and Paul Landefeld
By: Dowd, Timothy Jon
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Contributor(s): Landefeld, Paul.
Material type: 
ArticlePublisher: 2018Subject(s): IMPUESTOS | SOCIEDADES | RENTAS EXTRANJERAS | DEDUCCIONES | SISTEMA FISCAL | REFORMA | ESTADOS UNIDOSOnline resources: Click here to access online
In:
National Tax Journal v. 71, n. 4, December 2018, p. 729-750Summary: Public Law 115-97, commonly known as the Tax Cuts and Jobs Act, was passed at the end of 2017 and drastically altered the taxation of corporate income with fundamental changes to the treatment of cross-border income flows. We focus on the potential impact of one particular provision, the deduction for Foreign Derived Intangible Income (FDII) which provides a deduction for high return income derived from exports of goods and services. We form a historical panel of corporate tax returns and simulate the deduction for FDII had it been in place from 2000–2015. We find that the deduction would have provided significant benefits, particularly to firms in the manufacturing, information, and professional services sectors. We find these benefits to be highly concentrated. In addition, we find that deemed intangible income (DII) is pro-cyclical in nature — declining significantly as a share of income during recessions. The deduction for FDII exacerbated the pro-cyclical nature of DII during the 2001 recession, whereas during the Great Recession, exports moderated the pro-cyclical nature of FDII.
| Item type | Current location | Home library | Call number | Status | Date due | Barcode |
|---|---|---|---|---|---|---|
| Artículos | IEF | IEF | OP 233/2018/4-8 (Browse shelf) | Available | OP 233/2018/4-8 |
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Resumen.
Bibliografía.
Public Law 115-97, commonly known as the Tax Cuts and Jobs Act, was passed at the end of 2017 and drastically altered the taxation of corporate income with fundamental changes to the treatment of cross-border income flows. We focus on the potential impact of one particular provision, the deduction for Foreign Derived Intangible Income (FDII) which provides a deduction for high return income derived from exports of goods and services. We form a historical panel of corporate tax returns and simulate the deduction for FDII had it been in place from 2000–2015. We find that the deduction would have provided significant benefits, particularly to firms in the manufacturing, information, and professional services sectors. We find these benefits to be highly concentrated. In addition, we find that deemed intangible income (DII) is pro-cyclical in nature — declining significantly as a share of income during recessions. The deduction for FDII exacerbated the pro-cyclical nature of DII during the 2001 recession, whereas during the Great Recession, exports moderated the pro-cyclical nature of FDII.
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