Exhibit 674

Repatriating Offshore Funds: 2004 Tax Windfall for Select Multinationals

Exhibit 674 · Subcommittee report

Repatriating Offshore Funds: 2004 Tax Windfall for Select Multinationals

After repatriating over $150 billion under the 2004 American Jobs Creation Act (AJCA), the top 15 repatriating corporations reduced their overall U.S. workforce by 20,931 jobs, while broad-based studies of all 840 repatriating corporations found no evidence that repatriated funds increased overall U.S. employment.

Majority staff report on a survey of 19 to 20 repatriating corporations. Reports $312 billion repatriated at an effective 5.25 percent rate, a JCT revenue-loss estimate of $3.3 billion over ten years (about $100 billion would have returned anyway), net U.S. job losses at the top 15 repatriators, buybacks up 16 and 38 percent, and executive pay up 27 and 30 percent. Majority-staff (Democratic) authorship: findings on policy are one party's; the printed survey figures come from company responses. Local copy sha256 13ce026e18df1a9f75950430942b6f3f52a8fc3493b68c606daabbc7d0d27639.

Source: U.S. Senate Permanent Subcommittee on Investigations (majority staff)
Date: 11 October 2011
Quoted from: Report Findings, item 1 (report p. 5)
Grade: Primary record
Document: https://www.hsgac.senate.gov/imo/media/doc/RepatriatingOffshoreFundsReportOct202011wExhibitsFINAL.pdf
Accessed: 2026-11-10
Cited by: Findings citing this exhibit

Cited by

Finding POL-1.2: Primary record The 2004 repatriation provision taxed repatriated foreign dividends at an effective rate of 5.25 percent, and corporations repatriated $312 billion under it.
Finding POL-1.7: Primary record CRS reports that studies generally find the repatriated funds went to shareholders through stock repurchases. Dharmapala, Foley and Forbes estimate $0.91 of repurchases per $1 repatriated in their working paper.
Finding POL-1.8: Primary record A Democratic majority-staff report of the Senate Permanent Subcommittee on Investigations found that the top 15 repatriating corporations cut a net 20,931 U.S. jobs from 2004 to 2007 and raised stock buybacks 16 percent from 2004 to 2005 and 38 percent from 2005 to 2006.