"Unlike individuals, corporations don't want to be in that top 1 per cent," said analyst Andrew Chang, lead author of the S&P report. "This rising cash balance among the richest is tax-policy driven."
American multinationals are taxed by the country where profits are earned and by the US when - or if - the money is brought back. The corporate tax rate in the US, running up to 35 per cent, is the highest in the industrialised world.
Companies have long lobbied Congress to rewrite the code as cash for the wealthiest 1 per cent rose to 23.6 per cent as a share of total assets last year from 20.4 per cent in 2009, Chang found. For everyone else, it accounted for less than 7 per cent.
More acculumation
"Overseas cash continues to accumulate without being touched," Chang said. "It's undoubtedly going to increase."
That's bad for investors, who like to see money put to use or returned to shareholders. It's also not good for the deficit-ridden Treasury, which missed out on an estimated $83.4 billion in tax revenue this fiscal year as companies delay bringing back earnings, according to the congressional Joint Committee on Taxation.
And it can't buy happiness for one-percenters such as Medtronic that are taking drastic steps to make use of their earnings overseas. The medical-device manufacturer is taking some $13 billion it has offshore to buy a London-based competitor in an inversion, a merger which enables it to move headquarters abroad and pay lower taxes.
"Obviously we'd rather have our cash work for us because it's sitting in accounts with low interest rates and there'd be better ways to invest that money," said Fernando Vivanco, a spokesman for Medtronic. "Are there any companies that you know that could say we love having our cash trapped?"
Domestic assets
While Chang estimated 83 per cent of cash held by the wealthiest 1 per cent comes from foreign earnings, domestic assets are shrinking to the point that there's not always enough to finance US operations, he said.
That's one reason Apple, Cisco Systems and other one-percenters are borrowing. Cupertino, California-based Apple, which has 78 per cent of its $40.7 billion overseas, caused a stir last year when it said it would take on $17 billion in debt to make dividend payments. The company went back to the bond market in April.
It's cheaper to borrow against foreign cash than repatriate it, Cisco spokesman John Earnhardt said. Ninety-three per cent of the San Jose, California-based Cisco's $47.1 billion is held outside the United States.
"If a territorial tax were instituted or an acceptable level of corporate tax was instituted, we'd bring that money back," Earnhardt said. "Would it be better utilised here, where our corporate headquarters is? Yes."
Weighing inversions
While that borrowing has kept money circulating in the US economy, it's a holding pattern that can't be sustained if interest rates rise and prospects for tax legislation dim. That's why more executives are weighing mergers with foreign companies in order to lower taxes, said Douglas Holtz-Eakin, an unpaid adviser to the Alliance for Competitive Taxation, a Washington business group lobbying for tax reform.
"They've given up, they think there's no hope," said Holtz-Eakin, an economic adviser to former President George W. Bush. "And when the headquarters go, they're likely to put R&D next to the headquarters."
When Minneapolis-based Medtronic completes its merger with Covidien, it will get an Irish address and put future earnings out of reach of US tax collectors.
In May, London-based AstraZeneca rebuffed a similar overture from Pfizer. Drugstore chain Walgreen last week abandoned plans to change its address from Illinois to Switzerland when it completes a takeover of Alliance Boots.
Lew's warning
The Obama administration is trying to shut down such inversions after Treasury Secretary Jack Lew warned of a hollowing out of the corporate tax base.
"We should prevent companies from effectively renouncing their citizenship to get out of paying taxes," Lew wrote in a July 15 letter to lawmakers. "What we need as a nation is a new sense of economic patriotism."
Because multinationals reap much of their earnings outside the US, where markets are less developed and business is growing faster, it makes sense to keep at least some of that money abroad.
One-percenters Intel, General Electric and Hewlett-Packard keep cash abroad because that's where business is growing.
"There's a real need for us to maintain cash offshore," Intel spokesman Chuck Mulloy said. "The cash is there because we need it there."
Foreign earnings
US multinationals have accumulated $1.95 trillion in foreign earnings, up 11.8 per cent from a year earlier, according to a
Bloomberg
study. In addition to prompting inversions, the money has sent companies on an overseas buying spree.
GE, which operates in more than 170 countries, is using $57 billion in un-repatriated profits to buy France's Alstom. The deal will bring overseas acquisitions by US companies to more than $75 billion in 2014, slightly ahead of last year's pace, data compiled by Bloomberg show.
While the tax code gets blamed for dragging down the economy, freeing up foreign cash wouldn't necessarily stimulate growth. When more than 843 companies including Pfizer, Oracle and Merck, repatriated $312 billion during a 2004 tax holiday, the hoped-for job creation never materialised. Instead, stock buybacks and executive pay rose, giving a lift to individual one-percenters.
Richest Americans
"If they ended up paying out this money to stockholders, the lion's share is going to go to the top 1 per cent of individuals," said Thomas Hungerford, a senior economist at the Economic Policy Institute who wants to ban inversions. "But if you get the money back here and at least get it circulating, that will help the economy to some extent. It will certainly help our long-term federal budget problems."
And the corporate 99 per cent might reap the benefits.
"You could argue that companies that make a billion dollars and don't pay taxes are freeloaders," said Mitch Rofsky, president of the Better World Club, an insurer based in Portland, Oregon, and member of the American Sustainable Business Council, a group of small employers.
"It's basically an issue of do our economic models work, is infrastructure supported, does government have the money it needs," Rofsky said. "It's unfair."
- Bloomberg
