Analysis of the Strategic Optimization of the Foreign Derived Intangible Income Deduction of the Tax Cuts and Jobs Act of 2017 for Outbound U.S. Multinational Companies in the Industry of Digital Content Streaming
- Hetrick, Julie
- [University Park, Pennsylvania] : Pennsylvania State University, 2020.
- Physical Description:
- 1 electronic document
- Additional Creators:
- Jenkins, Edward Rowland and Schreyer Honors College
- Restrictions on Access:
- Open Access.
- This thesis researches and analyzes the impacts and opportunities for optimization of the Foreign Derived Intangible Income (FDII) deduction of the Tax Cuts and Jobs Act of 2017 (TCJA) for U.S. multinational companies, beginning with the rationale behind the legislation and then an analysis of the current implications through a hypothetical industry example. The analyses revealed that there is material room for optimization of the FDII deduction, specifically within the computation of a company's Qualified Business Asset Investment and portion of Deduction Eligible Income that is Foreign Derived. These findings are specific to U.S. multinational corporations that operate in the space of streaming digital content to foreign users with the opportunity for minimal foreign asset investment. This thesis also analyzed issues surrounding foreign income sourcing and the general effectiveness of the carrot and stick approach within federal legislation, specifically tax reform as reflected in the TCJA. The results indicate there is currently an opportunity for a material reduction in a multinational corporation's taxable income through the FDII deduction of the TCJA if strategic actions are taken.
- Dissertation Note:
- B.S. Pennsylvania State University 2020.
- Technical Details:
- The full text of the dissertation is available as an Adobe Acrobat .pdf file ; Adobe Acrobat Reader required to view the file.
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