U.S. Corporate Taxes, Inversions And Surplus Capital

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by: Marc Chandler


Walgreen's decision to pursue an inversion may mark the beginning of the end of such strategies.

The effective tax rate by large US multinational corporations that are profitable is near 17%, half the max Fed tax schedule.

A key imbalance leading to financial crisis is surplus savings and retained earnings by corporations contributes to this condition.

Walgreen's (WAG) decision to go ahead and buy the 55% of Alliance-Boosts that it does not own, but not move their headquarters may mark the beginning of the end of the so-called inversion boom. Inversion is simply when a US business buys a foreign company in a lower tax country and moves its headquarters there.

As this Great Graphic, from Goldman Sachs and published on Business Insider by Joe Wesienthal, illustrates there has been an explosion in such deals this year. The latest legislation was in 2004 that seemed to prevent or deter inter-company inversions, requiring actual transactions to accomplish this. There is a push for new legislation to close this loophole and there is some idea that the legislation could be retroactive.

While there is genuine concern, perhaps it is not too cynical to suggest that it also makes good copy for some candidates ahead of the November elections. The counter argument is two-fold. First, that addressing the perverse incentive structure should be part of the larger tax reform effort. Second, in some quarters the tax avoidance strategy is condoned as part of a criticism of the double taxation on corporate profits.

One of the big arguments is that the 35% top US federal corporate tax rate is among the highest in the world. It is little wonder then that corporations seek to minimize their tax burden, with inversions being simply one of the ways. Yet, we think the debate is all too often based on tax scheduled rates and not actual rates. What is the average rate that the large US multinational companies, who are doing these inversions to reduce their taxes, actually paying?

Large companies operating in other countries have to file special tax forms (M-3). According to the Government Accounting Office, the effective tax rate that is actually being paid is 22.7% in 2013. If only profitable companies are included, the effective tax rate is 17%.

This helps explain why corporate tax collection is relatively low. It is low on two counts. First, it is low relative to what the federal government has historically collected. As this Great Graphic, posted by Danielle Kurtzleben on Vox depicts the falling share of Federal corporate tax revenues compared with size of the economy and other taxes and revenues.

In 1952, corporate taxes revenue accounted for nearly a third of the federal revenue. By 2013, it had fallen below 10%.

Second, the taxes actually collected are relatively low as a percentage of GDP compared with other OECD countries. This final chart, was also posted on Vox by Kurtzleben. It shows that, on average, OECD countries collected 3% of GDP in corporate taxes. The US stood at 2.3% in 2011. In several countries, like Ireland and Luxembourg that are tax havens, corporate tax revenues are larger as a percentage of GDP than in the US.

We remarked recently that several major central banks, including the Federal Reserve, the Bundesbank, the Bank of Japan and the Bank of England all want to see an increase in wages. Higher wages are seen as either a signal that their economies have recovered sufficiently to normalize monetary policy (US and UK) or to ensure the economic recovery is not derailed (Japan and Germany).

If the problem is understood as insufficient aggregate demand, than boosting taxes on consumption (demand) as Japan did in April was counter-productive. Businesses, on the other hand, in the US, Europe and Japan are flush with cash and savings. Yet, despite low interest rates, net new capital investment (net of depreciation) remains meager at best. Besides, it has been several business cycles since investment led a recovery. Recent earnings data confirm that, generally speaking, profit margins remain fat. Cutting corporate taxes (as Japan plans and other countries consider) also seems counter-productive.

While some observers have attributed the financial crisis to global imbalances, perhaps there is another imbalance that contributed. Retained earnings that are not reinvested in plant and equipment have to be invested into something. If not real assets, the money is invested in paper assets. In addition to the large pools of capital by reserve managers (central banks and sovereign wealth funds) and large asset managers (pension funds, life insurers and mutual funds/unit trusts), corporate balance sheets should be included when analyzing why interest rates remain low.

Conventional wisdom holds that core bonds yields are low because of QE in both the US and Japan. That is the low long-term interest rates are artificial and a function of manipulation by central banks. One implication of the analysis here is that perhaps what is happening is a return of the Greenspan Conundrum.

The Greenspan Conundrum refers to the question the former Federal Reserve Chairman asked in the early 2000s: Why were long-term rates falling even though the Fed was raising short-term interest rates? Summer's resurrection of the secular stagnation hypothesis is a similar but different answer than Bernanke's answer to the conundrum: surplus savings.

Bernanke argued that the key was that after the Asian financial crisis, many countries in the region shifted from current account deficits to surpluses, yet did not have the capacity to absorb the new savings. They chose to export it and often bought US bonds. Bernanke also attributed a role to oil exporters as well, and recognized the role for demographics. The vast retained earnings of corporations in the high income countries maybe should be added to such surplus savings.

Disclosure: The author has no positions in any stocks mentioned, and no plans to initiate any positions within the next 72 hours. The author wrote this article themselves, and it expresses their own opinions. The author is not receiving compensation for it. The author has no business relationship with any company whose stock is mentioned in this article.