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Abstract

U.S. Multinational Companies, Dividends, and Taxes

by Ralph Kozlow

The passage of the American Jobs Creation Act of 2004 (AJCA) provided U.S. tax incentives for U.S. multinational companies that receive large dividends from their foreign affiliates. In 2005, dividends paid by foreign affiliates to their U.S. parents were 4 times as large as in 2004. With most international financial transactions, it is usually difficult for an observer to determine whether tax considerations were a primary factor in motivating the transactions versus just one of many important factors. However, given Congress’ stated motivation for passing the AJCA and the substantial increase in dividends received by U.S. parent companies after enactment, there certainly does appear to be a causal relationship (with tax considerations playing a primary role) in at least this instance.