How Does the U.S. Taxation of Foreign Earnings Affect Internal Capital Markets: Evidence from TIPRA 2005

I use the passage of the Tax Increase Prevention and Reconciliation Act of 2005 (TIPRA), which alters the after-tax considerations of foreign internal capital markets, as a quasi-natural experimental setting to test whether a reduction in the tax costs associated with moving foreign capital increased firms’ use of holding companies. In separate tests using Compustat and IRS data, I document that firms increase holding company use after TIPRA. Furthermore, I find that firms with the greatest increases in holding companies also increase their post-TIPRA foreign sales and generate more persistent foreign earnings. I interpret these findings to suggest that TIPRA is associated with increased global competitiveness for firms that actively modify their organizational structures. In additional analysis, I attribute this increased global competitiveness to maintained liquidity and capital investments during a financial crisis, relative to firms that do not respond as strongly to tax incentives to utilize holding companies.