‘Stay Put’ Decision
To be sure, the tax law has changed the calculus for some corporations. Drug maker Amgen Inc. said in April it would build a manufacturing plant in Rhode Island instead of Puerto Rico. Those are mostly one-offs, though, and tax experts say it’s unlikely to see a homecoming of software and patents already parked overseas.
Tax advisers said they were inundated earlier in the year with requests from multinationals about whether some of the tax law changes -- such as the Gilti tax and the minimum tax on offshore payments -- should prompt them to restructure their businesses and bring IP home.
Most companies decided they didn’t want to upend their tax planning because of uncertainty about how the various provisions of the law would interact and whether a future Democratic-controlled Congress would roll back some provisions of Trump’s overhaul.
There’s more confidence that lower-tax jurisdictions like Ireland will maintain their corporate tax regimes, according to Tom Zollo, a principal specializing in international tax at accounting firm KPMG.
“After doing some modeling, many have decided to stay put for a while,” Zollo said.
This article was provided by Bloomberg News.