The Unintended Consequences of Global Tax Asymmetries on Foreign Risk-Taking

Global tax asymmetries alter foreign investment incentives. The new US international tax regime, global intangible low-taxed income (GILTI), introduces a complex tax asymmetry based on taxable income and foreign capital structure factors, leading to incremental taxes on volatile foreign cash flows. I find empirical evidence consistent with US multinational enterprises responding to this asymmetry by decreasing foreign risk-taking. These changes appear to be attributable to decreasing foreign operational risks through the consolidation of overseas operations. This result is an unintended consequence for a provision that was designed to discourage firms from moving intellectual property to tax havens. These insights are relevant to proposed reforms to GILTI in the United States and for the anticipated rollout of the OECD’s new global tax framework.