In this paper, I talk about Section 965, also known as the transition tax, enacted in the Tax Cuts and Jobs Act (TCJA). First, I examine loopholes under the old tax regime that allowed for the accumulation of offshore earnings and how the TCJA closes those loopholes. After detailing the legislation of the transition tax and a comparison with Section 965 included in the American Jobs Creation Act in 2004, I compare firms’ recorded provisions of the transition tax with an estimation based on the past disclosures of firms’ permanently reinvested earnings and finds that the transition tax will generate an estimated $308 billion in tax revenue. Lastly, I propose three alternate scenarios to the transition tax: taxing all offshore earnings under the GILTI regime, treating offshore cash as eligible for the 21% corporate rate, and a ratable payment plan compared to the current phase-in payment plan.

The 2017 Tax Cuts and Jobs Act contained the largest federal initiative for place-based investment in over half a century. Opportunity Zones (“OZs”) are expected to cost the US government over $15 billion in forgone tax revenue through 2026, exceeding both the Clinton Era Empowerment Zones and the Great Society programs of Lyndon Johnson. Have OZs increased neighborhood investment and, if so, what types of projects and neighborhoods have benefitted? This dissertation presents three baseline evaluations of OZ. The first essay discusses the findings from 76 interviews with community and government officials, program managers, developers, businesses, and fund managers about OZ outcomes in West Baltimore. The second essay uses a difference-in-differences (DID) event study framework, an adjusted interrupted time series analysis, and census tract matching techniques to compare small business and residential lending outcomes in OZs with areas that were eligible but not designated. The final essay combines an online search for OZ supported affordable housing projects, a DID design that examines Low-Income Housing Tax Credit outcomes, and 16 interviews with community development experts to evaluate whether and how OZ is having an impact on affordable housing production. These three analyses show that OZ is a missed opportunity. OZ is stimulating investment conversations and local government capacity, but it is failing at oversight and community engagement and not changing outcomes for distressed community development or affordable housing. OZ is failing because it provides weak incentives for capital gains investors seeking market rate returns, because it does not support investors and developers already active in distressed neighborhoods, and because of several related design flaws that inhibit mission driven development. The essays propose specific policy changes necessary for OZ to encourage investment in highly distressed neighborhoods and to support affordable housing production.

No description available.