Kimberly Clausing (Reed College) has published Tax Holidays (and Other Escapes) in the American Jobs Creation Act, 58 National Tax Journal 331-46 (Sept. 2005). Here is the abstract:

This paper considers the international tax incentives created by the American Jobs Creation Act of 2004. The temporary dividend repatriation tax break is evaluated in the context of previous theoretical and empirical work. While this tax break is likely to lead to a surge in temporary repatriations, it is unlikely to encourage new investment in the United States. Instead, the tax break sends a confused message about the intent of the U.S. tax system and, together with the other international tax provisions in the legislation, is likely to encourage foreign investment in low–tax countries.