The Business Cycle and the Deduction for Foreign Derived Intangible Income: A Historical Perspective

Timothy Dowd () and Paul Landefeld

National Tax Journal, 2018, vol. 71, issue 4, 729-750

Abstract: Public Law 115-97, commonly known as the Tax Cuts and Jobs Act, was passed at the end of 2017 and drastically altered the taxation of corporate income with fundamental changes to the treatment of cross-border income flows. We focus on the potential impact of one particular provision, the deduction for Foreign Derived Intangible Income (FDII) which provides a deduction for high return income derived from exports of goods and services. We form a historical panel of corporate tax returns and simulate the deduction for FDII had it been in place from 2000-2015. We find that the deduction would have provided significant benefits, particularly to firms in the manufacturing, information, and professional services sectors. We find these benefits to be highly concentrated. In addition, we find that deemed intangible income (DII) is pro-cyclical in nature - declining significantly as a share of income during recessions. The deduction for FDII exacerbated the pro-cyclical nature of DII during the 2001 recession, whereas during the Great Recession, exports moderated the pro-cyclical nature of FDII.

Date: 2018
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