If US companies bring back billions from overseas, who profits?

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American companies — led by giant biopharma and high-tech businesses — have stashed a staggering amount of money overseas to avoid paying taxes in the United States.

An estimated $2.4 trillion in profits from foreign sales sit in accounts outside of the country. But a big chunk of those riches could be sent home if President-elect Donald Trump makes good on his promise to cut the 35 percent US corporate tax rate, one of the highest in the world.

If that happens, what might US companies do with the windfall?

If you're thinking more hiring or investment in domestic drug research, you might end up being disappointed.


For instance, Amgen Inc.'s chief financial officer last month told stock analysts that he had a good idea of how the biotech giant might spend some of the $34 billion it has parked abroad: "We'd look at certainly deploying cash . . . toward external opportunities," said David W. Meline. That's business-speak for buying other companies.

Drug makers like Amgen would stand to be among the largest beneficiaries of a lower corporate tax rate. Those with ties to the Boston area include Cambridge-based Biogen Inc., which had about $5 billion overseas as of Sept. 30, while Merck & Co. and Pfizer Inc., which run large research labs in the region, had $21 billion and $14 billion overseas, respectively, according to the research firm Evercore ISI.

None of the Boston-area companies would comment on how they plan to use repatriated money.

The new administration hopes to draw the overseas cash as part of a broader effort to reform the tax system and bankroll ambitious government infrastructure programs. Even at a reduced rate — which hasn't yet been specified — taxes on this new money could raise tens of billions for the federal government.

That would amount to a stimulus plan, which has been embraced in general terms by Trump and some of his allies. The anticipation has helped fuel a stock market run-up since the Nov. 8 election.


The main boost to the economy would come from the inflow of corporate tax revenue that could fund an infrastructure bank to finance the construction of highways, bridges, airports, and other projects that Trump has said are top priorities.

But a secondary benefit is possible if companies use some of the newly repatriated cash to hire workers, build plants, buy equipment, or expand drug-research programs. It sounds great, but companies already are telegraphing that they're more likely to do what Amgen is planning — acquire competitors — as well as repurchase their own stocks to drive up share prices, or to pay dividends to investors.

"There'll be a lot of pressure [from Wall Street] to give the money back to shareholders" through dividends or stock buybacks, said Chuck Marr, director of federal tax policy at the Center on Budget and Policy Priorities, a Washington, D.C., think tank. "It could be embarrassing to the people who are predicting all this business investment in the United States."

It wouldn't be the first time. Marr pointed to 2004, when the George W. Bush administration granted a one-time tax "holiday" for companies to repatriate their cash hoards, temporarily lowering the corporate rate to 5.25 percent.

While the express aim was to create jobs and stir economic activity, he said, the estimated $350 billion infusion led to a flurry of stock buybacks and takeovers by companies, including some that eliminated jobs.


"It was a fire sale," Marr said. "Across the board, it was considered a complete failure."

Whether that scenario is repeated might hinge on how the new administration structures a repatriation plan. If it's part of a broader tax reform that lowers the corporate rate permanently and is applied retroactively, companies might not be so inclined to view it as a temporary cash bonanza.

Businesses would also welcome a so-called territorial tax system under which the United States would not levy a tax on foreign profits that were already subject to taxes in the countries where the companies had recorded those sales.

"The international tax system that the US has relied on for the past three or four decades is broken," giving companies incentives to keep cash offshore, said Mihir A. Desai, a professor of finance at Harvard Business School. "Crazy stuff is going on in the world because of taxes. It's become so bad that the most important merger-and-acquisition transactions are driven by tax considerations."

As an example, he cited a wave of tax "inversions" in which US-based corporations have acquired companies based in lower-tax countries, including Ireland and Switzerland, and then shifted their corporate addresses abroad for tax purposes. One prominent example was Minneapolis-based Medtronic Inc's takeover of Covidien PLC, which had its management in Mansfield but its global headquarters in Ireland, a deal that let Medtronic become an Irish company.


"There's a big pot of money out there," said Desai, who predicted a tax overhaul would lead to some US hiring by biopharma companies and other businesses as well as investments that would spur economic activity. "We want a system that rewards companies for investing in the United States."

One of the unintended consequences of the current system is that it creates incentives for US companies to invest in other countries. Biotech companies like Biogen and Sanofi Genzyme, which is also based in Cambridge, manufacture some drugs in Europe. Analysts say more medicines could be produced here under a reformed corporate tax system.

"All things being equal, companies might want to have manufacturing closer to home," said Glen Giovannetti, global biotechnology practice leader at the consulting firm Ernst & Young in Boston. "If money comes back into the United States, it's capital that's now available to be spent here. They might decide to set up plants here rather than Europe."

.  .  .

An estimated $2.4 trillion in profits from foreign sales sits in accounts outside the United States. On Sept. 30, biopharma cash overseas included:

 Amgen: $34 billion

 Gilead: $25.2 billion

 Merck: $21 billion

 Pfizer: $14 billion

 Eli Lilly: $7 billion

 AbbVie: $6 billion

 Biogen: $5 billion

SOURCE: Evercore ISI

Robert Weisman can be reached at robert.weisman@globe.com. Follow him on Twitter @GlobeRobW.