One goal of the Tax Cuts and Jobs Act of 2017 was to
increase repatriation of overseas earnings. Broadly speaking, new repatriated
earnings are not subject to additional taxes that were in force under the
previous tax system. A common misconception is that most of the $3 trillion in
foreign earnings earned held abroad by U.S. companies was sitting in stockpiles
of cash. In the second quarter of 2018, companies repatriated
$169.5 billion, which is up significantly from the $34.9 billion in the second
quarter of 2017, but down from the $294.9 billion repatriated in the first
quarter of 2018. Several factors have reduced the expected tax windfall, including
a company’s desire to leave cash overseas for investment to foreign laws that
limit a company’s ability to repatriate cash to the U.S.