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The devilish detail - The spoils from American corporate tax reform are

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All-American firms benefit the most, multinationals less

IT S always a lot of fun when you win, President Donald Trump enthused after

his tax package was approved by Congress in December. Company bosses nodded

along. The centrepiece of the reform is a drastic cut to the corporate-tax

rate, from 35% to 21%, taking it below the rich-country average. Although its

impact is partly offset by some revenue-raising measures, the congressional

Joint Committee on Taxation estimates that American business will gain around

$330bn from the reform over the next ten years. Yet within that are sizeable

variations in terms of which firms and industries benefit most.

The biggest winners are more domestically oriented companies. These typically

face higher effective tax rates than American companies with a big presence

overseas, which do business in lower-tax countries. Bosses are also evaluating

other new measures. So-called full expensing , for example, helps those with

big spending plans by allowing them to deduct investment costs up front. But

using debt will become less attractive, as interest payments are no longer

fully deductible.

ome firms experienced high volatility in their earnings for the final quarter

of 2017 thanks to the treatment of so-called deferred tax assets . These are

past tax losses carried forward to set against future tax bills, and such

assets have shrunk in value because of the lower corporate-tax rate. Other

firms that hold deferred liabilities enjoyed big one-off gains.

Of the 150 S&P-listed companies that have so far released estimates of their

effective tax rate for 2018, telecoms and consumer-focused companies (which

often have a big American presence) expect to have gained the most, says

Ramaswamy Variankaval of J.P. Morgan, an investment bank (see chart). AT&T, a

telecoms giant, predicts a rise in cashflow of $3bn in 2018, or nearly a fifth

of cashflow last year.

Multinational firms do benefit from a lower American headline tax rate. They

will also pay a much lower tax rate, of 15.5%, on foreign cash that is

repatriated. Yet while they were previously taxed only when the money was

brought home, now they must cough up and pay tax on all of their $3trn

stockpile of foreign cash over an eight-year period.

Other changes to the treatment of foreign income are more controversial. The

new base-erosion anti-abuse tax , or BEAT, applies to all big firms operating

in America and targets cross-border payments to foreign affiliates, such as

royalties on intellectual property. Firms must now add such services back into

their American corporate earnings, and pay a 10% tax (after 2018, until when a

5% rate applies) on this broader base if it exceeds the standard calculation of

21% on a narrower base. Another new tax charge applies only to American firms

that have global intangible low-taxed income or GILTI returns on intangible

assets, such as patents or software, parked abroad.

Both BEAT and GILTI were intended to prevent companies from dodging tax by

stashing intellectual property and other intangibles in tax havens, notes

Jennifer Blouin, from the University of Pennsylvania. But, as drawn up, they

are much broader, she says, and could capture all foreign affiliates, even if

they already pay high tax rates, such as those in Germany. That has irked some

European firms.

With bureaucrats still transcribing the hastily drafted legislation into rules

for business, firms cannot yet be sure of their total impact. But many

technology and pharmaceutical companies, even though together they hold the

most cash abroad, anticipate slightly lower tax rates as a result of the

reforms, says Mr Variankaval. Even Apple, which booked a $38bn tax payment on

its $250bn mountain of foreign cash (it has yet actually to pay it), expects a

net benefit. In contrast, some other firms, such as IBM and General Electric,

expect slightly higher tax rates in 2018 than they paid last year, as the wider

tax base offsets the lower headline rate.

Unsurprisingly, the reforms appear to negate the benefits of inversion , or

setting up abroad for tax purposes. Valeant and Allergan, both drugmakers

domiciled abroad, expect higher tax rates. It is too early to tell, though, if

the tax changes will succeed in shifting supply chains and intangible assets

back to America.

It is also too early to gauge how the winners will spend their gains. According

to Americans for Tax Reform, a lobbying group, 377 companies have announced pay

awards linked to the tax reform, including AT&T and American Airlines. Most are

bonuses that amount to a small part of the total gains, leading sceptics to

attribute the announcements to clever public relations. A few firms have gone

further, announcing permanent wage increases or new investment projects. But

these were probably in the pipeline anyway, given improving demand, says Matt

Gardner, from the Institute on Taxation and Economic Policy, a think-tank.

That said, most analysts do expect the lower corporate-tax rate to make

investing in America more attractive in the longer term. But if the past is any

guide, argues Ms Blouin, repatriated earnings will mostly be returned to

shareholders. Last week Cisco, a tech company, said that was precisely what it

would do with most of the $67bn it was bringing home. Like Mr Trump, investors,

too, are in for some fun.

This article appeared in the Business section of the print edition under the

headline "The devilish detail"