Repatriation - Repatriation of Currency

Repatriation of Currency

When foreign currency is converted back to the currency of the home country it is referred to as repatriation. An example would be an American converting British pounds back to U.S. dollars.

Repatriation also refers to the payment of a dividend by a foreign corporation to a US corporation. This happens often where the foreign corporation is considered a "controlled foreign corporation" (CFC), which means that if more than 50% of the foreign corporation is owned by US shareholders. Generally, foreign direct investment in CFC's are not taxed until a dividend is paid to the controlling US parent, and is thus repatriated. The foreign direct investment income of the CFC is taxed only by the country where it is incorporated until repatriation. At that time, income is subject to the (typically higher) US tax rate minus the Foreign Tax Credits.(FN: See IRC 951-965) There are currently hundreds of billions of dollars of Foreign direct investment in CFC's because of the disincentive to repatriate those earnings. (See Bureau of Economic Analysis, National Economic Accounts, Integrated Macroeconomic Accounts for the United States, available at the Bureau of Economic Analysis.