There are two ways Congress can exploit this offshore cash to raise money while cutting taxes.

• One is what’s known as a repatriation holiday. Congress could create a special window of time during which overseas cash could be brought back home at a discount rate. Corporate America would pay the discount rate, and shareholders would get dividends that they also pay taxes on. This would increase short-term revenue, while giving a huge break to CEOs and wealthy shareholders. Congress tried this in 2004 on the theory that it would lead companies to boost investment and create jobs. That didn’t happen, according to a landmark study by Dhammika Dharmapala, C. Fritz Foley, and Kristin J. Forbes, who found that “repatriations did not lead to an increase in domestic investment, employment or R&D, even for the firms that lobbied for the tax holiday stating these intentions.” Later studies agree.
• The other option, which has gained popularity since the repatriation holiday concept has been largely discredited, is that you could permanently cut the tax rate on foreign profits and then retroactively apply the new lower rate to foreign-held cash, which would be “deemed” repatriated for tax purposes. In this new scheme, Congress would straightforwardly admit that the purpose of the repatriation is to generate tax revenue, with the investment coming from spending the money on infrastructure rather than from the businesses themselves.

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