The tax cut law that became effective on January 1, 2018 incentivizes companies that have stashed cash overseas to avoid a 35 percent corporate tax rate to bring that money back to the U.S. A one-time charge of anywhere between 8 and 15.5 percent applies to these repatriated funds.
Citigroup estimates that U.S. firms are holding more than $2.6 trillion abroad. Apple alone is responsible for $252.3 billion of these funds. Microsoft’s overseas cash pile amounts to $132 billion.
Since the law was enacted, a number of companies have announced their intention to take advantage of the much-reduced tax rate to repatriate cash they have stashed outside the U.S. Apple, Citigroup, Goldman Sachs, Bank of America, American Express, and JP Morgan Chase are among the companies that have announced their intention to repatriate overseas cash.
These and other repatriating firms are not under any restrictions as to how to use their cash bonanzas. Policymakers, of course, prefer that they reinvest in their businesses because this would do the most to stimulate economic growth. If they go this route, these companies become prime targets for generating new legal and law-related job opportunities.
However, if these funds are applied to share repurchases, that would cut down on the potential number of new legal jobs. Share buybacks are an attractive temptation because they generally result in immediate share price appreciation and signal investors that company shares are undervalued.
Goldman Sachs predicts that the companies that will benefit most from cash repatriation are those that hold the most cash overseas relative to their market capitalization. Translated into employment sectors, that means technology and healthcare firms. General Electric, Cisco, Citrix Systems, Amgen, Western Digital, Waters, Oracle, and Qualcomm fall into this category.
Targeting firms that are likely to be the biggest beneficiaries of this component of the tax law is a strategy that both experienced attorneys seeking to change jobs and graduating law students should incorporate into their job search campaigns.