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Unpacking Discrepancies in American and Irish Royalty Reporting
Ireland’s elimination of a controversial tax avoidance strategy appears to be driving a recent increase in royalty payments from Ireland to the U.S.
Journal Article
The Impact of the 2017 Tax Cuts and Jobs Act on U.S. Multinationals' Intangible Assets
This article investigates the impact of the 2017 Tax Cuts and Jobs Act (TCJA) on the intangibles of U.S. multinationals. We develop a theoretical model that incorporates key provisions of the TCJA—Global Intangible Low-Taxed Income (GILTI) and Foreign-Derived Intangible Income (FDII)—and derive testable implications for changes in licensing and patent transfer patterns. Using data on international royalty flows and patent assignments, we test the model’s predictions. Our findings suggest that the TCJA may have impacted profit-shifting strategies through intangibles, aligning with our ...