Apple Repatriation Tax Bill Suggests Tax Score Keepers Were Way Off the Mark

Apple’s plan to make a massive repatriation tax payment suggests that the government’s official score-keepers may have vastly underestimated the near-term revenue gains from the recently enacted tax reform.

Apple said Wednesday it would make a tax payment of $38 billion related to offshore cash holdings. That amounts to 15 percent of its $252.3 billion of offshore cash, in line with the 15.5 percent rate included in the new tax law.

That’s nearly half of the total amount of additional revenue the Joint Committee on Taxation (JCT) estimated would be generated in 2018 by the mandatory repatriation. With that much additional revenue coming in from a single company — albeit the largest holder of offshore cash — it now seems very likely the JCT’s estimate of $78.6 billion will turn out to be a sizable underestimation.

While the exact amount of offshore cash held by U.S. companies is unknown, reliable estimates range from between $1.4 trillion to $2.8 trillion. Apple’s share of that is, then, between just nine percent and 18 percent of the total. Even if just a half of the $1.4 trillion results in repatriation revenue at a rate similar to Apple’s in 2018, that would mean an additional $105 billion of additional revenue in 2018 — 34 percent higher than the JCT’s estimate.

Perhaps other companies will not be as aggressive as Apple. But since the tax bill erased the incentive to hold cash offshore, it is more likely that Apple is a leading indicator here. This will likely mean that the near term revenue boost from tax reform will be higher and budget deficits will be much lower than estimated.