Susan M. Albring (University of South Florida, School of Accountancy), Ann Dzuranin (Ph.D. candidate, University of South Florida, School of Accountancy) & Lillian F. Mills (University of Arizona, Eller College of Business and Public Administration) have posted Tax Savings on Repatriations of Foreign Earnings Under the Jobs Act, 108 Tax Notes 655 (Aug. 8, 2005), also available on the Tax Analysts web site as Doc 2005-16098, 2005 TNT 152-30. Here is the abstract:
The authors estimate the incremental tax savings from the 85% deduction for cash dividends from permanently reinvested earnings under the American Jobs Creation Act of 2004. Using 2,196 corporations that report foreign assets or foreign sales in 2002, they find that 282 corporations both report an amount of permanently reinvested earnings and have a foreign tax rate of less than 35%. Without the Jobs Act, those 282 firms would have paid an estimated incremental U.S. tax of $46 billion on repatriation. Under the Jobs Act, those firms would save $39 billion, resulting in incremental tax of $7 billion on immediate repatriation



