Tax Cuts And Jobs Act Research Articles

The Trump Tax Penalty and Its Impact on the Economy

The Tax Cuts and Jobs Act (TCJA) was signed into law by former President Donald J. Trump in 2017.The law took effect on January 1, 2018.The law permanently cut the corporate tax rate to 21% and temporarily lowered individual tax rates. Evidence in this paper will demonstrate how an older married couple on Social Security and a modest pension actually incurred higher federal income taxes during the years 2018- 2021 as a result of TCJA. Paying higher federal income taxes as a result of TCJA is the Trump Tax Penalty.

Tax Policy Expectations and Investment

ABSTRACTThis paper examines how firms’ tax policy expectations (TPE) evolve around and relate to their investment responses to changes in tax policy. Using a text‐based approach to measuring TPE, we find that two recent tax policy–changing events—namely, the 2016 U.S. presidential election and the enactment of the Tax Cuts and Jobs Act (TCJA)—spawned considerable between‐ and within‐firm variation in TPE, with aggregate time‐series patterns in TPE occasionally challenging prevailing assumptions in previous research. Further, we observe that event‐induced TPE relate to investment both before and in response to the TCJA's passage in 2017, with offsetting associations between its first and second moments, and that these TPE moderate the TCJA's intended investment‐stimulating effect. Furthermore, we document a difference between domestic and multinational firms in their TPE‐investment response, with the former (latter) more likely to adjust the level (shift the country location) of their investment. Overall, our findings support the idea that TPE can impact investment behavior in the face of a tax policy change and suggest that our methodology can be used by future research to incorporate TPE into analyses of tax policy effects.

More Tax, Less Refi? The Mortgage Interest Deduction and Monetary Policy Pass-Through

We study how the mortgage interest deduction (MID) affects refinancing. Households who deduct mortgage interest from their taxes face a lower post-tax mortgage rate, reducing the interest savings from refinancing net of taxes. We estimate the effect of the MID on refinancing using the Tax Cuts and Jobs Act (TCJA) of 2017 as a natural experiment. The TCJA doubled the standard deduction, reducing MID uptake and value. We show that, following the TCJA, the refinancing rate amongst households who lose the MID increased by 25%. Our results suggest that reducing the MID may improve the pass-through of monetary policy when rates fall.

Assessing the Impact of the 2017 Tax Reform on College Athletic Donations Related to Ticket Sales

The Tax Cuts and Jobs Act (TCJA) of 2017 affected many traditional tax deductions for a variety of organizations. One that went under the radar for many, except those in the college sport ecosystem, was the removal of a deduction for donations related to college sport ticket sales. Developed from the Technical and Miscellaneous Revenue Act of 1988, IRC §170(l) provided individual taxpayers the ability to claim 80% of the amount paid over the value of tickets to college athletic events as a charitable contribution. TCJA eliminated this itemized deduction, which concerned several university athletic directors about the long-term effects of this change on their program’s revenue generation. This article assesses the history of the development and application of IRC §170(l) and determines whether these contributions should have been allowed as a charitable deduction overall. The article also examines the impact of IRC §170(l) after TCJA’s implementation, finding the athletic directors’ collective feared impact of reduced contribution revenues was not significant based on available data. Donors appear motivated by more than just the tax benefit, and the removal of the deduction did little to affect overall contributions.

Sharing the Wealth: The Effects of Announced TCJA Bonuses on Employee Pay Satisfaction

ABSTRACT Many corporations publicly announced plans to share windfalls from the Tax Cuts and Jobs Act (TCJA) with rank-and-file employees. We examine the association between these bonus announcements and workers’ pay satisfaction. Although employees are better off upon receiving the bonuses, prior literature suggests employees can be dissatisfied with awards they perceive as small or inequitable. By linking the bonuses to a corporate tax windfall, firms provided a reference point for employees to assess fairness. Using a difference-in-differences design, we find a greater decline in pay satisfaction at firms announcing a TCJA bonus relative to firms that do not. We also provide evidence of greater dissatisfaction among employees who perceive their share of the windfall as unfairly small. Considering increasing income disparity in the U.S. and a heightened focus on corporate taxes, we provide new and timely insights into how workers respond to changes in compensation linked to corporate tax savings. Data Availability: Data are available from the sources cited in the text. JEL Classifications: H25; M52.

Heterogeneity in Corporate Tax Incidence by Worker Characteristics

We study how corporate tax incidence on worker earnings varies across worker characteristics: gender, age, and employment tenure. To do so, we examine effects of the corporate tax cuts introduced by the Tax Cuts and Jobs Act (TCJA), using data from federal tax records and a difference-in-differences empirical design. We find no systematic differential effects by gender but find that TCJA resulted in larger earnings gaps for older workers and long-tenured workers. These gaps become larger towards the top of the within-firm earnings distribution.

U.S. multinational corporations' income shifting incentives and share repurchases: Evidence across differential taxation systems

This study examines the association between income-shifting incentives and share repurchases using a sample of US multinational corporations (MNCs) from 2006 to 2020. We find a significant negative (positive) association between income shifting and share repurchases before (after) the enactment of the Tax Cuts and Jobs Act (TCJA) in 2018. The results show that the TCJA only had a short-term effect on the relation between income shifting and share repurchases that was largely confined to 2018 and reverted to pre-TCJA levels in subsequent years. Additionally, the overall negative relationship between income shifting and share repurchases is stronger in firms with high repatriation costs. However, firms with an advance pricing agreement with the Internal Revenue Service evidence a positive association between income shifting and share repurchases. Overall, we provide evidence for the effects of taxation system reforms on MNCs' income-shifting incentives and share repurchase decisions.

Fiscal Year-Ends and Financial Benefits: The Role of Prospective Measurement Dates in Tax Reform

ABSTRACT The Tax Cuts and Jobs Act (TCJA) of 2017 dramatically reshaped the tax landscape for companies and reduced incentives for multinationals to leave foreign earnings abroad. We study a provision of the law that allowed some multinationals to take simple measures to reduce their tax burden more than other firms. The TCJA levied a tax on accumulated income held in foreign subsidiaries of U.S. firms. The implementation of this tax left firms an avenue to protect shareholder wealth, as foreign income retained as “cash” was taxed at a higher rate (15.5 percent) than foreign income retained in other asset classes (8 percent). Measurement rules allowed some firms significantly more time to shift foreign cash holdings to “noncash” assets and lower their tax burden. Using staggered, firm-specific measurement dates, we find that fiscal year-end firms with more time to respond to the law reduced their cash levels more than other firms. JEL Classifications: E62; H21; H25.

Did the Tax Cuts and Jobs Act stimulate capital expenditures? A firm-level approach

ABSTRACT We investigate whether the Tax Cuts and Jobs Act (TCJA) of 2017 motivated firms to increase capital investments. Using a unique approach that identifies firm-level tax benefits and incentives introduced by the TCJA, we find that firms that realized tax benefits increased their investment in fixed assets in the following year. Specifically, as a result of the change, an increase in forecasted earnings and an increase in nonrecurring tax benefits stimulated growth in capital investments. We also find that the investment-inducing effect of the TCJA was larger for firms with a higher cost of capital and for those with better alignment between management and shareholder interests. Although our study is not able to explain the long-term consequences of TCJA, it improves upon the previous literature demonstrating that the mixed findings of previous studies may be the result of the unequal distribution of tax benefits among firms.

The TCJA and Domestic Corporate Tax Rates

We study changes in tax positions for U.S. C corporations following passage of the 2017 tax legislation commonly known as the Tax Cuts and Jobs Act (TCJA). While existing research has focused primarily on publicly traded companies, data limitations have prevented more holistic analyses of the corporate sector. Using a representative sample of U.S. corporate tax returns, we highlight how trends in effective tax rates (ETRs) and exposure to the legislation’s main provisions varied for public, private, multinational, domestic, and large versus small firms. We document several novel facts, including that ETRs increased on average for privately held, domestic firms and for firms in the bottom 90% of the firm sales distribution after TCJA. In contrast, public, multinational, and large firms saw substantial ETR cuts on average. We find that firms' pre-TCJA exposure to changes in the corporate tax rate and treatment of net operating losses have the strongest correlation with post-TCJA ETR changes. Overall, the analysis underscores the divergent impacts of TCJA on different firm types and illuminates the economic scope and relative significance of TCJA’s myriad provisions.

“Just BEAT it” do firms reclassify costs to avoid the base erosion and anti-abuse tax (BEAT) of the TCJA?

This study empirically examines whether firms reclassify related-party payments to avoid the base erosion and anti-abuse tax (BEAT) of the Tax Cuts and Jobs Act (TCJA). We leverage the BEAT filing threshold and use both a difference-in-differences design among U.S. firms and a triple-difference design utilizing the parent company's location to provide evidence that firms reclassify related-party payments to avoid the BEAT. This effect is stronger in firms with greater pre-TCJA income shifting incentives. We estimate a $6 billion aggregate reduction in U.S. taxes for our sample firms in 2018. We also examine the consequences of reclassifying related-party payments and find some evidence of an increase in tax reserves and a reduction in internal information quality for firms that engage in cost reclassification to avoid the BEAT. These findings help explain observed BEAT collection shortfalls, contribute to the current policy debate about international tax reform, and document spillover effects of tax policy.

The impact of TCJA on CEO compensation

The 2017 Tax Cuts and Jobs Act (TCJA) expanded the impact of IRC Section 162(m) by disallowing a tax deduction for any compensation over $1 million paid to top executives. Under prior law, qualified performance-based compensation was exempt from the $1 million limit. Using OLS regressions, we examine whether TCJA affected CEO compensation immediately after enactment. We find evidence that CEO salaries, non-equity incentive pay, stock awards and total compensation are all higher after TCJA. While the law change increases the after-tax cost of compensation for the average firm, our results show that TCJA did not constrain CEO compensation. However, relative to the average effect, in cross-sectional analyses, we find some evidence that compensation was lower for strong CEOs post TCJA. We also find some evidence that CEOs at firms with high leverage and net deferred tax assets, including tax net operating losses, saw a decrease in various types of incentive compensation post TCJA.

Nonprofit Planning and Impact with Regard to the 2018 Tax Law

The Tax Cuts and Jobs Act (TCJA) is considered the largest tax overhaul since 1986 and was anticipated to produce declining charitable donations for nonprofits and was expected to create disruption across the nonprofit sector in 2018. This study tests whether small nonprofits (under $250,000 in revenues) or large nonprofits (over $250,000 in revenues) planned differently due to the law and secondly, how they were affected by the law. Utilizing survey data from 50 nonprofits, this research offers qualitative data on both large and small nonprofit organizational awareness as it relates to the rollout of the law.

Nebraska Approves Pass-Through Entity Tax Bill

In 2023, the Nebraska Legislature passed a bill that allows a partnership or S-Corp to elect to pay its state income taxes. Previously, because the income from the partnership or S-Corp is passed through to the owner, the owners of the entity paid the taxes at their own individual tax level. In 2018, the federal government passed the Tax Cuts and Jobs Act (TCJA), which limited the itemized deduction for state and local taxes in the individual’s return to $10,000. This prompted many states to adopt laws like the new Nebraska law to work around this limitation. Federal tax law allows entities to deduct state income taxes paid as an ordinary business expense, but for most states this has only been allowed for C-corporations since they are the only entity to pay their own taxes. The pass-through entity tax law expands that option.

DONOR-ADVISED FUNDS IN THE WAKE OF THE TAX CUTS AND JOBS ACT

Donor-advised funds (DAFs) are conduits for charitable giving that support immediate tax deductions while creating a reservoir of assets for subsequent disposition to end-use charities. The number of new DAF accounts has skyrocketed in the wake of the 2017 Tax Cuts and Jobs Act (TCJA). This Article presents evidence suggesting that bunching charitable contributions to more fully exploit the TCJA-enhanced standard deduction likely motivates much of the onslaught of new DAF accounts established since 2016 and argues that the typical buncher is likely to differ from other DAF account holders in ways that matter from a policy perspective. Thus, while DAF critics have generally focused on the unproductive accumulation of assets in DAF accounts and have advanced reforms aimed at speeding up DAF payouts, this Article argues that in the context of bunchers, unproductive accumulation of assets in DAF accounts is unlikely to be a major problem. The more significant problem with DAF-facilitated bunching is that the cost to the public fisc is unlikely to be justified by incremental charitable giving. Thus, while this Article concludes that regulation targeting DAF payouts is unobjectionable, it argues that a wholly different set of reforms targeting the deductibility of charitable giving generally would be needed to address the cost of DAF-facilitated bunching under current law and under thoughtfully reformed laws involving universal charitable deductions above a floor.

Shifting incentives: the impact of the Tax Cuts and Jobs Act on S bank conversions

PurposeThis paper investigates the significant increase in S corporation banks converting to C corporations following the 2017 Tax Cuts and Jobs Act (TCJA) and the shift in motivations behind these conversions.Design/methodology/approachThe paper uses bank-level panel data from Federal Deposit Insurance Corporation (FDIC) Call Reports to analyze the determinants of S bank conversions after the TCJA, comparing post-TCJA conversion trends with pre-TCJA trends utilizing an ordinary least squares (OLS) and logistics model.FindingsThe study finds that post-TCJA conversions are primarily driven by financially stable banks seeking improved tax conditions and relaxed shareholder restrictions as C corporations. This contrasts with pre-TCJA conversions, which were predominantly driven by financially distressed S corporation banks seeking new equity capital to maintain solvency.Research limitations/implicationsThe findings necessitate a comprehensive reconsideration of the Subchapter S status' sustained relevance for smaller institutions, especially in light of the comparative benefits now offered by the C corporation status post-TCJA. The results underscore the importance of ongoing academic investigation to deepen the understanding of the evolving fiscal landscape's effects on community banks, thereby contributing to the knowledge of the resilience and health of the US economy.Practical implicationsThis research nudges policymakers and regulators to contemplate the ongoing relevance and advantages of the S corporation status. Given the substantial benefits conferred by the C corporation status in the post-TCJA environment, this study suggests that retaining the S corporation status may not offer the same appeal for smaller community banks as it once did.Originality/valueThis paper contributes to the broader understanding of the impact of tax policy on businesses' organizational choices, particularly in the banking industry and emphasizes the need for a comprehensive review of the S corporation status to assess its ongoing applicability in fostering small and community-focused financial institutions in light of the evolved corporate tax landscape.

Repatriation tax and dividend policy

AbstractThis paper examines the impact of the repatriation tax provision of the Tax Cuts and Jobs Act (TCJA) on firms’ dividend policy. Our findings show that the firms most affected by the repatriation tax provision, that is, those with high foreign sales, reward shareholders by substantially increasing dividends per share, but maintain aggregate dollar dividends. Dividend per share (DPS) increasing firms repurchase at significantly higher magnitudes than non‐dividend per share increasing firms, suggesting that DPS increasing firms partially utilize repurchases to avoid substantial increases in their long‐term aggregate dividend commitments. We also investigate whether managers reap the rewards of dividend increases, finding that firms with high levels of executive ownership and foreign sales are more likely to increase their dividends per share after the TCJA was enforced. Overall, our results highlight the importance of the interconnection between dividends and repurchases in examining the response of firm payout policy to external shocks.

Tax In History: Acknowledging (Celebrating? Regretting?) Sixty Years of Subpart F

Deferral of home-country tax on the income of foreign subsidiary corporations produces the twin evils of business and investment location distortion and profit shifting. In 1961, the Kennedy administration proposed the almost complete elimination of this type of deferral from the US income tax system. Because of strong opposition lobbying, the result was a political compromise commonly known as Subpart F. This article explains why Subpart F was largely a failure, in spite of its being copied to various degrees by the controlled foreign corporation (CFC) regimes of many developed countries. The article also explores the extent to which the 2017 Tax Cuts and Jobs Act (TCJA) has, or has not, cured Subpart F’s failure to effectively address location distortion and profit shifting. Deferral, profit shifting, Subpart F, CFC regimes, US international income taxation, 2017 Tax Cuts and Jobs Act

The effect of US tax reform on the taxation of US firms' domestic and foreign earnings

AbstractWe quantify the immediate net effect of the Tax Cuts and Jobs Act (TCJA) on the tax burden of corporate profits for public US corporations. We find similar reductions in effective tax rates for domestic and multinational firms, yet the entirety of multinational tax savings stemmed from tax savings on their domestic, not foreign, earnings. We find no significant change in the federal tax burden on foreign earnings neither on average norspecifically for firms most likely to be subject to new anti‐abuse provisions. We find some evidence that firms not targeted by anti‐abuse provisions saw reductions in their federal tax burden on foreign income. Overall, while the tax burden on domestic income decreased significantly, our findings suggest the tax burden on the foreign earnings of US multinationals is largely unaffected despite the overhaul of the international tax system. Importantly for US multinationals' investment decisions, while foreign income was heavily tax‐favored prior to tax reform, we find that foreign and domestic incomes are similarly taxed after TCJA enactment.

Nonprofit Planning and Impact with Regard to the 2018 Tax Law

The Tax Cuts and Jobs Act (TCJA) is considered the largest tax overhaul since 1986 and was anticipated to produce declining charitable donations for nonprofits and was expected to create disruption across the nonprofit sector in 2018. This study tests whether small nonprofits (under $250,000 in revenues) or large nonprofits (over $250,000 in revenues) planned differently due to the law and secondly, how they were affected by the law. Utilizing survey data from 50 nonprofits, this research offers qualitative data on both large and small nonprofit organizational awareness as it relates to the rollout of the law.