Question
Q corporation has reinvested $100 billion of foreign earnings in its Irish operations. Due to a change in economic conditions, its pre-tax Irish ROA has
Q corporation has reinvested $100 billion of foreign earnings in its Irish operations. Due to a change in economic conditions, its pre-tax Irish ROA has declined to 5 percent. Under pre-2018 tax law, it estimates that it would have had to pay $25 billion in US tax to repatriate all of these earnings and profits to the US. What pre-tax return would the company have needed to earn in the US to break even, after tax, on repatriation of its Irish E&P? In other words, what pre-tax return (ROA) would it have had to earn to generate as much income, after-tax, on the $75 billion to be reinvested in the US as it would have earned on the $100 billion if it did not repatriate the earnings? Assume an Irish tax rate of 12.5% and a US tax rate of 35%.
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