The impact of US tax depreciation law on asset location and ownership decisions

The decision of whether to manufacture products within the US, manufacture internationally or to outsource production depends critically upon a thorough understanding of the costs and benefits of each option. In this paper, we contribute to such an understanding by considering the impact of US tax depreciation rules, which differ depending upon whether a US corporation locates its assets at domestic or foreign branches. Our analysis and illustrative examples demonstrate that US depreciation law can indeed have a non-trivial impact on location and sourcing decisions, with direct ownership of foreign assets appearing relatively less attractive once depreciation law is taken into account. More broadly, our results demonstrate that comprehensive asset location and ownership decisions require a detailed understanding of international tax law, rather than just a simple recognition of differences in tax rates among countries.