This paper examines the determinants of profit repatriation policies for US multinational firms. Dividend repatriations are surprisingly persistent and resemble dividend payments to external shareholders. Tax considerations influence dividend repatriations, but not decisively, as differentially-taxed entities feature similar policies and some firms incur avoidable tax penalties. Parent companies requiring cash to fund domestic investments, or to pay dividends to common shareholders, draw on the resources of their foreign affiliates through repatriations. Incompletely controlled affiliates are more likely than others to make regular dividend payments and to trigger avoidable tax costs through repatriations. The results indicate that traditional corporate finance concerns - taxation, costly external finance, and agency problems - are also critical to the internal capital markets of multinational firms.
Hines, James R., Jr. "Dividend Policy Inside the Multinational Firm." M. A. Desai and C. F. Foley, co-authors. Fin. Mgmt. 36, no. 1 (2007): 5-26.