File 023069
BofA Merrill Lynch Equity Strategy Report: Corporate Tax Reform Analysis (File 023069)
Bank of America Merrill Lynch equity strategy report analyzing the potential impacts of corporate tax reform on S&P 500 earnings, including tax rate cuts, repatriation, border adjustment taxes, and interest deductibility changes.
Summary
This January 2017 equity strategy report by BofA Merrill Lynch's U.S. Equity & Quant Strategy team examines the estimated financial impacts of proposed corporate tax reform, using House Speaker Paul Ryan's Blueprint as a baseline with Trump administration scenarios. The analysis projects that cutting the corporate tax rate from 35% to 20% could add approximately $8 to S&P 500 EPS, while repatriation of overseas cash could generate an additional $4 per share through buybacks. The report quantifies negative impacts from border adjustment taxes ($5-6 per share) and elimination of interest expense deductions (4% of EPS), with total near-term impacts ranging from $0.50 to $10.00 per share depending on the final tax rate enacted. The analysis includes industry-specific beneficiaries and victims of tax reform, recognizing that potential negative impacts on certain sectors could affect the likelihood of legislative passage.
Equity Strategy Focus PointDeath and tax reformQuantitative Analysis29 January 2017 CorrectedUnauthorized redistribution of this report is prohibited. This report is intended for amanda.ens@baml.comDeep dive on corporate tax reformOK, maybe it’s not as inevitable as death and taxes, but some form of corporate taxreform seems likely. It is a stated priority of President Trump and has widespreadCongressional support. We here focus on four components that could have big equityimplications. We assess the impacts at a market, sector, and industry level, and plan toupdate and augment this work as more details come to light.Potential near-term boost to EPS, long-term impact variesOur 2018 S&P 500 EPS estimate of $137 already implies healthy two-year growth of +16%.Tax reform in its entirety could add as much as $5-6 to near-term EPS, as benefits are frontloaded.The sustained impact depends: under a 20% tax rate, the Blueprint would bemodestly accretive; under a 15% rate, this annual benefit could triple; but a 25% tax rate thatwould appease the deficit hawks could shave $3.50 off of earnings each year. We alsoestimate a one-time $8-9 charge to GAAP EPS associated with the repatriation tax (Table 1).Cutting corporate tax rate could add $8 to EPSOur starting point is the US statutory corporate tax rate. If it were lowered from 35% to20% and the US moved to a territorial tax system (no longer taxing foreign profits), itwould boost S&P 500 EPS by an estimated 12% ($17 to 2018 EPS). We assumecompanies would be able to retain half of the benefit ($8) and the remainder would bepassed on to customers or competed away. For instance, a lasting impact to Utilities'profits is unlikely, as the benefit would be passed on via regulated pricing.Repatriation: Buybacks could boost EPS by 3%Both Trump and the Blueprint support a mandatory (as opposed to 2004's optional) taxof overseas earnings of US firms’ subsidiaries at reduced rates. Non-Financials in the S&Phold at least $1.2tn in overseas cash (mostly Tech and Health Care). If half was used forbuybacks, this could add 3% ($4) to S&P 500 EPS. A redux of 2004 where companiesused 80% of cash for buybacks may be less likely, in our view. For if repatriation isaccompanied by an end to interest expense deductions, companies may choose to paydown debt over buybacks.Border adjustment tax (BAT) hits EPS by $5-6While Trump has described the BAT as being “too complicated,” White House presssecretary Spicer’s recent comments call into question his stance. This is a keycomponent of the Blueprint and would generate significant revenue. First-order impactscould be significant, with border adjustments detracting $5-6 from 2018 EPS — nearly80% of the drag comes from the consumer sectors. The second order impacts — productpricing, pricing within the supply chain, exchange rates, foreign policy reactions, etc. —while harder to quantify, are important to consider.End to interest deductibility could detract 4% from EPSWe estimate that over time, the removal of the interest expense deduction woulddetract about 4% from S&P 500 EPS. An increase in the cost of debt by an incremental25% could have longer term ramifications for capital structures and funding..Tax reform winners and losersWe include stock screens for potential beneficiaries and victims of tax cuts, repatriationand interest deductibility changes, as well as industries most helped/hurt most by a BAT.Note that the very fact that there are companies and industries that have the potentialto be very negatively impacted could call into question the likelihood of passage.BofA Merrill Lynch does and seeks to do business with issuers covered in its research reports. As aresult, investors should be aware that the firm may have a conflict of interest that could affect theobjectivity of this report. Investors should consider this report as only a single factor in makingtheir investment decision.Refer to important disclosures on page 26 to 27. 11706251Timestamp: 29 January 2017 12:01AM ESTEquity and Quant StrategyUnited StatesSavita SubramanianEquity & Quant StrategistMLPF&S+1 646 855 3878savita.subramanian@baml.comDan Suzuki, CFAEquity & Quant StrategistMLPF&S+1 646 855 2827dan.suzuki@baml.comMarc PoueyEquity & Quant StrategistMLPF&S+1 646 855 1142marc.pouey@baml.comAlex MakedonEquity & Quant StrategistMLPF&S+1 646 855 5982alex.makedon@baml.comJill Carey Hall, CFAEquity & Quant StrategistMLPF&S+1 646 855 3327jill.carey@baml.comJimmy BonillaEquity & Quant StrategistMLPF&S+1 646 556 4179jimmy.bonilla@baml.comTable 1: Estimated impact of tax reform on S&P 5002018 EPSTax policy 15% 20% 25%Tax rate change 10.50 8.00 5.00End int. deduct. – init. impact* -0.50 to -1.00 -0.50 to -1.50 -0.50 to -2.00Border adjustments -4.00 -5.50 -6.50Repatriation buybacks 4.00 4.00 4.00Total init. Impact 9.50 to 10.00 5.00 to 6.00 0.50 to 2.00End int. deduct. – recur. impact -3.50 -5.00 -6.00Recurring impact 7.00 1.50 -3.50One-time repat. tax -8.50 -8.50 -8.50Source: BofAML US Equity & Quant Strategy, FactSet, Compustat, S&P*Assumes end to interest deductibility only applies to new debt, where we estimate70-90% of debt is long-term.Note: For this exhibit, we assume that 100% of the cash is repatriated and 50%of it is spent on buybacks. For different buyback assumptions, please see thesection on repatriation.ContentsThe costs and benefits of tax reform 3Cutting the corporate tax rate 4Repatriation 6Border adjustment tax analysis 12Closing loopholes 15No interest tax shield 17Tax reform screens 19Related BofAML research on US tax reform 22Methodology 242 Equity Strategy Focus Point | 29 January 2017The costs and benefits of tax reform2017 could be a watershed year from a tax reform perspective. Trump has continuouslystated that tax reform is a priority, and there is evidence of widespread support inCongress. Tax reform could be enacted through reconciliation without the risk of beingfilibustered, suggesting the timing could be imminent. Corporate tax reform could havea significant impact on S&P 500 earnings, corporate behavior and capital markets. Muchhas been written on the timing, funding and process by which corporate tax reformcould be enacted. In this report, we use House Speaker Paul Ryan’s Blueprint proposal asa starting point in quantifying the impact of corporate tax reform on the S&P 500, withsome scenario analysis to account for differences included in the final bill (such asTrump’s proposals). Our analysis is focused specifically on the impact of corporate taxreform, however we recognize that there are many other factors that can impact thesensitivity analysis (e.g. changes to household income tax rates, infrastructure spending,etc.).We estimate that the Blueprint proposal would initially boost S&P 500 EPS by $5-6,assuming the end of interest expense deductions only applies to new debt, or is phasedin over time. But the devil is in the details. Over time, the loss of the interest tax shieldwould be a significant drag on earnings as existing debt is refinanced. Additionally, thecorporate tax rate is critical in determining whether or not the tax reform policies endup being accretive to earnings on a sustained basis. We estimate that at the 20% taxrate, the Blueprint would be modestly accretive, the benefit would triple under Trump’sproposed 15% tax rate, but at a higher 25% tax rate that would appease the deficithawks in Congress, the benefit would turn to a negative over time (Table 2). We alsoestimate a one-time $8-9 charge to GAAP EPS that would be associated with thediscounted repatriation tax.Table 2: Estimated impact of tax reform on S&P 500 2018 EPSTax policy 15% 20% 25%Tax rate change 10.50 8.00 5.00Ending interest deductibility – initial impact* -0.50 to -1.00 -0.50 to -1.50 -0.50 to -2.00Border adjustments -4.00 -5.50 -6.50Share count reduction from buybacks (50%) 4.00 4.00 4.00Total initial impact 9.50 to 10.00 5.00 to 6.00 0.50 to 2.00Ending interest deductibility – recurring impact -3.50 -5.00 -6.00Recurring impact 7.00 1.50 -3.50One-time repatriation tax (8.75%), GAAPcharge -8.50 -8.50 -8.50Source: BofAML US Equity & Quant Strategy, FactSet, Compustat, S&P*Assumes end to interest deductibility only applies to new debt, where we estimate 70-90% of debt is long-term.Note: For this exhibit, we assume that 100% of the cash is repatriated and 50% of it is spent on buybacks. For different buybackassumptions, please see the section on repatriation.In the following pages, we focus on the following topics that have large implications forUS equity investors, but it is important to consider corporate tax reform holisticallyrather than drawing major implications from each measure in isolation:• Reducing the US corporate tax rate• Repatriation - mandatory tax on overseas profits• Border adjustment tax• Removal of interest expense deductionThe government revenue associated with each of these is included in the table below.Equity Strategy Focus Point | 29 January 2017 3Table 3: Estimated 10-year* revenue impact from tax plans, $bnBased on estimates from both the Tax Policy Center and Tax FoundationHouse Plan Trump PlanCorporate Tax Reform -890 to -1200 -1940 to -2630Lower corporate tax rate (20% under House, 15% under Trump) -1800 to -1850 -2120 to -2350Full capex expensing, interest expense no longer deductible (mandatory underHouse, choice between two under Trump)** -450 to -1040 -320 to -590Deemed repatriation of overseas earnings 140 to 190 150-200Move to territorial tax system -90 to -160 n/aBorder adjustment 1070 to 1180 n/aChanges to individual income/payroll taxes -980 to -2020 -2190 to -3730Repeal estate/gift taxes -190 to -240 -170 to -240Total (static) estimate -2420 to -3100 -4370 to -6150*Tax Foundation assumes impact over 2016-2025 and Tax Policy Center assumes impact over 2016-2026**Under House plan, Tax Foundation separately breaks out estimates for full capex expensing (-$2236) and disallowing interest deductionon new loans (+$1194).Note: estimates rounded to nearest ten billion, with range to incorporate estimates from both sources. Other elements to corporate taxreform not itemized above include eliminating the AMT, repealing certain corporate tax deductions, etc.Source: Urban-Brookings Tax Policy Center, Tax Foundation, BofA Merrill Lynch US Equity & US Quant Strategy (calculation of ranges)From a sector and industry perspective there are haves and have-nots based on eachpolicy, but in aggregate most sectors have some puts and some takes based on taxreform. The table below shows some relevant aggregate statistics by sector that informour subsequent analysis.Table 4: Estimated overseas cash vs. last 12 month effective tax rate vs. COGS net exports by sectorSectorEst. cashoverseas ($bn)Overseas cash% mkt capEffective taxrate LTMNet % imported vsexported COGSDiscretionary 75 2.9% 28% -14%Staples 68 3.2% 29% -13%Energy 39 2.6% 21% -3%Health Care 187 7.0% 23% -4%Industrials 127 6.0% 26% 1%Technology 647 14.9% 20% -9%Materials 24 4.0% 23% 3%Telecom 1 0.2% 29% 0%Utilities 2 0.3% 28% 0%S&P 500 ex. Financials & Real Estate 1,170 5.7% 25% -6%Source: BofAML US Equity & Quant Strategy, FactSet, BloombergCutting the corporate tax rateThe best starting point for analyzing corporate tax reform is the US statutory corporatetax rate, as this rate is critical in determining the impact of other proposed changes(border adjustments, interest deductibility, etc.). If the tax rate were lowered from 35%to 20% and the US moved to a territorial tax system (no longer taxing foreign profits),all else equal, we estimate an initial boost to S&P 500 EPS of 12% ($17 to 2018 EPS).However, over time, some of this benefit could be passed on to customers via lowerprices — for instance, it is unlikely that there will be any major long-lasting impact fromtax reform for Utilities sector profits, as any benefit/cost would likely be passed throughto customers when incorporated into each company's regulated pricing. The benefitwould also be offset by some of the other changes discussed in subsequent sections.We assume that S&P 500 companies would be able to retain half of the benefit, orroughly $8 of 2018E EPS. Below, we show the estimated EPS impacts on each sectorbased on a tax rate of 20%.4 Equity Strategy Focus Point | 29 January 2017Chart 1: Sector EPS estimated impact from 20% rate0% 2% 4% 6% 8% 10% 12% 14% 16% 18% 20%FinancialsDiscretionaryTelecomStaplesIndustrialsHealth CareEnergyMaterialsInfo TechReal Estate2%4%8%10%10%14%12%12%16%18%Source: BofAML US Equity & Quant Strategy, FactSet, S&PWhile the effective tax rate of the S&P 500 is generally about 28% (currently closer to25% due to the recent commodity recession), we estimate that the tax rate for the S&P500’s domestic operations is much higher at roughly 33% — although this includesstate and local taxes. If all companies with tax rates above the proposed new tax rate of20% were to drop to 20%, and no companies provisioned for US taxes on foreignprofits, we estimate the domestic effective tax rate for the S&P 500 would fall in linewith its foreign tax rate of roughly 19%. This would represent a 9ppt decrease in thecurrent S&P 500 tax rate and a 12% increase in EPS. We show the sensitivity to S&P500 EPS to different assumed tax rates in the chart below, but we reiterate that theseestimates exaggerate the actual impact on profits, as a significant portion of thesebenefits would likely be passed on to consumers via lower prices. We assume that inaggregate, roughly half of the gains from the lower tax rate would be retained (i.e. halfof the amounts shown in the sensitivity analysis in Chart 2).Table 5: Impact of 20% domestic corporate tax rateSector Current tax rate New tax rate ChangeDiscretionary 30% 19% -12pptStaples 29% 20% -9pptEnergy 41% 32% -9pptFinancials 33% 21% -11pptHealth Care 25% 16% -9pptIndustrials 32% 23% -9pptInfo Tech 18% 14% -4pptMaterials 28% 23% -5pptReal Estate 9% 7% -2pptTelecom 29% 20% -9pptUtilities 32% 20% -12pptS&P 500 28% 19% -9pptSource: BofAML US Equity & Quant Strategy, FactSet, S&P* Current tax rates may differ from other sources, as this analysis is based on companies’ 5-yr medianfiscal year domestic and foreign tax data from annual filings.Chart 2: Benefit to 2018 S&P 500 EPS from lower tax rates20%15%10%5%0%$10.50 $8.0015% 20% 25%New Corporate Tax RateEstimated impact on 2018 EPS$5.00Source: BofAML US Equity & Quant StrategyNote: Our base case assumes that half of the benefit would be passed on to customers, competedaway or offset by other changes to the tax code. Thus, we would expect the uplift to our EPS forecastto be roughly half the calculated benefit from simply lowering the corporate tax rate.The market is beginning to price in the benefits of tax cuts , but we may still be in theearly days – note that potential beneficiaries of fiscal stimulus (i.e. infrastructurespending) have seen an 18% multiple re-rating but de minimis fundamental support,whereas potential beneficiaries of lower corporate tax rates have seen performancedriven nearly equivalently by multiples and earnings.Equity Strategy Focus Point | 29 January 2017 5Chart 3: Decomposition of performance of 1) S&P 500 stocks exposed to fiscal stimulus* and 2) top50 S&P 500 stocks with the highest L12M effective tax rates, vs. rest of S&P 500 (1/31/16-1/23/17)25%20%15%10%5%20%2%18%15%7%19%11%8% 8%15%6%9%0%Stimulus BeneficiariesS&P 500 ex-StimulusBeneficiariesHigh Effective Tax RateListChg in PE Chg in EPS PerformanceS&P 500 ex-High Eff TaxRate List*Stocks identified by BofAML analysts as stimulus beneficiaries in 150 stocks with exposure to the Fiscal Stimulus theme 21 Aug. 2016Source: FactSet, BofA Merrill Lynch US Equity & US Quant StrategyPotential beneficiaries: See Table 19 at the end of this report for a screen ofdomestically-oriented companies with high effective tax rates which couldpotentially benefit from a lower corporate tax rate.RepatriationRepatriation likely under both Blueprint and Trump plansMandatory tax on overseas profits of 8.75% under Blueprint, 10% under TrumpThe US currently operates under a tax system in which the domestic earnings of UScorporates are taxed at the federal US corporate rate (35%) and any overseas earningsthat are repatriated are taxed at this rate less a credit for foreign taxes paid on thosesame earnings. Many multinationals’ foreign earnings thus remain parked offshore,allowing corporations to avoid the tax hit associated with bringing them back to the US.Both Trump and the House (under Ryan) have proposed a mandatory tax of overseasearnings of US firms’ foreign subsidiaries at reduced rates, such that this cash can bebrought back and put to work in the US. This differs from the 2004 repatriation taxholiday, which was optional.Under the Blueprint, accumulated overseas earnings will be subject to a transition tax of8.75% 1 (for those held in cash/cash equivalents) or 3.5% (for all other holdings), withcompanies able to pay the tax liability over an eight-year period. This would be part ofbroader tax reform, where a proposed territorial tax system would exempt companies’foreign income from US taxes and prevent future buildup of overseas profits ascompanies would be free to bring them home. Trump’s plan calls for a one-time deemedrepatriation of overseas corporate profits at a 10% tax rate.Table 6: Blueprint vs. Trump tax plans for taxing offshore earnings of US firms’ foreign subsidiariesPlanTax rate on accumulated overseas earningsBlueprint8.75% for cash/cash equivalents, 3.5% of all other holdingsTrump tax plan 10%Source: donaldjtrump.com, abetterway.speaker.govThe Tax Policy Center estimates that a repatriation tax holiday would generateapproximately $150bn in tax receipts under Trump’s plan (over 10 years) and $140bn1Note: The effective tax rates of 8.75% and 3.5% under the Blueprint are based on an allowable deduction of 75% (fordeferred earnings held in cash/liquid assets) or 90% (for the non-cash portion), with the remainder taxed at the UScorporate tax rate, i.e. 35%(1-75%) = 8.75% and 35%(1-90%) = 3.5%. This methodology was proposed by Dave Camp’s(former chairman of the House Committee on Ways and Means) Tax Reform Act of 2014.6 Equity Strategy Focus Point | 29 January 2017under the Blueprint (over eight years). The Tax Foundation similarly estimates that arepatriation act could drive spending amounting to $185-200bn in revenues through2025, which could help fund infrastructure/defense spending.S&P 500 companies could bring back over $1tn – mostly in Tech & Health CareOur FX team has written that US corporates in aggregate (including Financials) hold~$2tn in cash overseas, and their work suggests that nearly half is concentrated within20 companies. Similarly, as we discuss below, half of the repatriated cash following the2004 Homeland Investment Act came from just 15 companies, predominantly in Pharmaand Tech. Our own analysis of the S&P 500 (based on filings and estimates from ouranalysts) suggests that non-Financials in the S&P hold approximately $1.2tn overseas,nearly three-quarters of which is in Tech and Health Care (Chart 4).Chart 4: Estimated overseas cash as a % of mkt. cap by sector for the S&P 500 (excludes Financialsand Real Estate)Overseas cash as a % of market cap16%14%12%10%8%6%4%2%0%TechHealth CareIndustrialsS&P 500 ex. Fins. &Real Estate*MaterialsStaplesCons. Disc.EnergyUtilitiesTelecomNote: Overseas cash based on company disclosures where available, BofAML analyst estimates, and BofAML US Equity & Quant Strategyestimates using overseas sales as a guide where the former two were not available. For some companies, analyst estimates are for totalaccumulated overseas profits (which may not all be in cash). *S&P ex. Fins. & Real Estate cash is as a % of total S&P 500 market capSource: Bloomberg, FactSet, BofA Merrill Lynch US Equity & US Quant Strategy, BofA Merrill Lynch Global ResearchRepatriation in context: a look back at 2004The last repatriation holiday in the US was the Homeland Investment Act (HIA) of 2004(part of the American Jobs Creation Act), which allowed for a one-time repatriation offoreign earnings by US multinationals at a reduced effective tax rate of 5.25% (vs. thestatutory 35% rate), based on an allowable exemption of 85% of foreign earnings fromUS taxes (35% x [1-85%] = 5.25%). This deduction could be claimed in the tax yearbeginning before or after the passage date in Oct. 2004. Approximately $300bn wasrepatriated, according to the Bureau of Economic Analysis (BEA)’s U.S. InternationalTransactions Accounts Data, vs. an average of $60bn over the prior five years. The IRSestimates 2 that 843 US companies took advantage of the act.Despite HIA’s intent; most repatriated cash was spent on buybacks/dividendsDespite the U.S. Treasury Department’s guidelines that repatriated earnings should bespent on capital investment, R&D, M&A, and other pro-growth uses such as hiring, thiswas not ultimately the result: the National Bureau of Economic Research (NBER)estimates 3 that $0.92 of every $1.00 brought back was used to return cash toshareholders ($0.79 for buybacks and $0.15 for dividends) 4 , and that repatriationultimately did not lead to a pick-up in capex, employment or R&D. In fact, a 2011 reportby US Senate Permanent Subcommittee on Investigations 5 found that the top 152Redmiles, Melissa: “The One Time Received Dividend Deduction”, https://www.irs.gov/pub/irssoi/08codivdeductbul.pdf3Dhammika Dharmapala, C. Fritz Foley, and Kristin J. Forbes: “Watch What I Do, Not What I Say: The UnintendedConsequences of the Homeland Investment Act”, NBER Working Paper No. 15023, June 2009,http://www.nber.org/papers/w15023.pdf.4 The $0.79 for buybacks and $0.15 for dividends does not sum to the $0.92 cash return figure due to theNBER’s calculation methodology.5United States Senate Permanent Subcommittee on Investigations: “Repatriating Offshore Funds: 2004 Tax Windfallfor Select Multinationals”, Majority Staff Report, October 11, 2011Equity Strategy Focus Point | 29 January 2017 7repatriating companies—which accounted for 52% of the total repatriated amount—actually reduced their US workforce and decreased their R&D spending following therepatriation act. The authors of the NBER study point out that cash is fungible, andfirms were able to bypass the guidelines on how repatriated cash should be used.Table 7 shows the top 15 repatriating companies following the HIA, and IRS estimatesfor the proportion of repatriated cash by industry are in Table 8.Table 7: Top 15 repatriating companies based on the 2004 HIACompanyRepatriated Amount ($bn)Pfizer 35.5Merck 15.9Hewlett Packard 14.5Johnson & Johnson 10.7IBM 9.5Schering-Plough 9.4Bristol Myers 9.0Eli Lilly 8.0DuPont 7.7Pepsi Co, Inc. 7.4Intel 6.2Coca-Cola 6.1Altria 6.0Procter & Gamble 5.8Oracle 3.1Source: Data provided by corporations in response to U.S. Senate Permanent Subcommittee onInvestigations surveyTable 8: Corporations Repatriating Dividends Under IRC Section 965,Selected Items, by Selected Major and Minor Industry of the ParentCorporation, Tax Years 2004-2006Industry% of Repatriated Cash DividendsPharmaceutical and medicine manufacturing 29%Computer and electronic equipment manufacturing 19%Other manufacturing 8%Food manufacturing 6%Other chemical manufacturing 5%Information (including software publishers) 4%Finance, insurance, real estate, rental and leasing 4%Transportation equipment manufacturing 3%Management of companies and enterprises 3%All other industries 2%Paper manufacturing 2%Machinery manufacturing 2%Electrical equipt, appliance & component manufacturing 2%Other services 2%Basic chemical manufacturing 2%Fabricated metal product manufacturing 1%Retail trade 1%Wholesale trade, nonduarable goods 1%Wholesale trade, durable goods 1%Profiessional, scientific and technical services 1%Transportation and warehousing 0%Plastics and rubber products manufacturing 0%Primary metal manufacturing 0%Note: all figures are IRS estimatesSource: IRS (https://www.irs.gov/pub/irs-soi/08codivdeductbul.pdf)Our data for the S&P 500 similarly suggests that share repurchases saw the biggestpick-up in terms of cash use from when the HIA was passed in October 2004 throughthe end of 2006. Buybacks jumped over 200% over this period, where they went from12% of operating cash flows to 33% of operating cash flow by the end of 2006.Chart 5: Capex, dividends, buybacks and M&A for the S&P 500 ex-Financials: increase from10/31/2004-12/31/2006 and % of Operating Cash Flow during both dates60%250%% of Operating cash Flow50%40%30%20%10%0%200%150%100%50%0%Capex Dividends Net Buybacks Acquisitions% of OCF - 10/31/2004 (LHS) % of OCF - 12/31/2006 (LHS) % increase (RHS)% increase 10/31/04-12/31/06Source: FactSet, BofA Merrill Lynch US Equity & US Quant Strategy(https://www.hsgac.senate.gov/subcommittees/investigations/media/new-data-show-corporateoffshore-funds-not-trapped-abroad-nearly-half-of-so-called-offshore-funds-already-in-the-united-states)8 Equity Strategy Focus Point | 29 January 2017No alpha from repatriation and multiples actually compressedOur analysis of the top 15 repatriating companies (from Table 7) suggests that whilethese companies initially outperformed both the S&P 500 and equal-weighted S&P 500from November 2004-April 2005 (by 6ppt and 5ppt, respectively), they subsequentlyunderperformed during the remainder of 2005 and early 2006 (Chart 6). From the end ofSeptember 2004 through year-end 2006, these stocks were up 27% on average, in-linewith the overall S&P 500, and below the equal-weighted benchmark’s 36% return. Andmultiples for these stocks compressed over the majority of this period, both on anabsolute basis and relative to the benchmark (Chart 7).Chart 6: Cumulative relative performance (equal-weighted) vs. S&P 500and EW S&P 500 of Top 15 repatriating companies, 9/30/04-12/31/06Chart 7: Fwd. P/E of Top 15 repatriating companies – absolute andrelative to the S&P 500 median fwd. P/E, 9/30/04-12/31/06106.0104.0102.0100.098.096.094.092.090.088.086.0Sep/04Oct/04Nov/04Dec/04Jan/05Feb/05Mar/05Apr/05May/05Jun/05Jul/05Aug/05Sep/05Oct/05Nov/05Dec/05Jan/06Feb/06Mar/06Apr/06May/06Jun/06Jul/06Aug/06Sep/06Oct/06Nov/06Dec/0623.022.021.020.019.018.017.016.0Sep/04Nov/04Jan/05Mar/05May/05Jul/05Sep/05Nov/05Jan/06Mar/06May/06Jul/06Sep/06Nov/06Top 15 Fwd P/E (LHS)1.501.401.301.201.101.000.90Top 15 vs. S&P 500 Top 15 vs. EW S&P 500Top 15 Rel Fwd P/E vs. Median S&P 500 Fwd P/E (RHS)Source: U.S. Senate Permanent Subcommittee on Investigations survey (for Top 15 repatriatingstocks), FactSet, Bloomberg, BofA Merrill Lynch US Equity & US Quant StrategySource: U.S. Senate Permanent Subcommittee on Investigations survey (for Top 15 repatriatingstocks), FactSet, BofA Merrill Lynch US Equity & US Quant StrategyPost-repatriation cash use: will this time be different?Valuations, investor preference, growth & leverage ratios suggest less buybacksWhile any potential restrictions on the use of repatriated earnings are still unknown, wesuspect that a pick-up in buybacks is likely, but that a lower proportion will be used forbuybacks today than during the last repatriation holiday. Valuations were generally moreattractive in 2004-2005 on most metrics (Table 9), and we’ve found that buybacks tendto be more rewarded when stocks are cheap (Chart 8). Additionally, the largest buybackshave not generated alpha for the last several years, as investors have increasinglyagitated for companies to use their excess cash on pro-growth investments (namelycapex.) According to BofAML’s latest Global Fund Manager Survey, 60% of investorswant companies to increase capex spending, vs. 17% who want companies to returncash to shareholders (Exhibit 1). This compares to a majority of investors desiringcompanies to return cash to shareholders when the HIA was passed in late 2004.Companies may also feel less pressure to bolster per share metrics by reducing sharecount if top line is recovering and organic growth is finally materializing. And from acapital structure perspective, if leverage loses its tax benefit, given that leverage ratiosare already high (see below) companies may be less likely to reduce their equity capitalbase, as that would marginally increase their weighted average cost of capital.Special dividends, pay-down of debt may be other likely usesCompanies may also return the cash to shareholders by issuing a one-time specialdividend: income remains in-demand, given that both interest rates and dividend payoutratios remain historically low. And if a repatriation tax holiday comes within the contextof broader tax reform that includes an end to the deductibility of interest expense,companies may choose to pay down debt over other uses of cash, in an attempt to skewtheir balance sheets less toward debt and more toward equity (see the section on noEquity Strategy Focus Point | 29 January 2017 9interest tax shield later in this report). Deleveraging balance sheets may also be spurredby a continued environmwnt of rising interest. Leverage for S&P non-Financials hassteadily been ticking up over the last few years, and, if we exclude the cash-richTechnology sector, leverage is approaching all-time highs (Chart 9).Table 9: S&P 500 valuations: October 2004 vs. todayMetric 10/31/2004 Today (12/31/16)Fwd P/E 15.6 16.9Trailing P/E 16.7 22.0Median Fwd P/E 16.2 17.3P/B 2.8 2.9EV/EBITDA 11.6 11.7P/S 1.5 2.0EV/Sales 2.2 2.3Source: FactSet, S&P, BofA Merrill Lynch US Equity & US Quant StrategyChart 8: Average Annual Return of Russell 1000 Top Quintiles by factor(1986-present)16%14%12%10%8%10.0%11.7%13.5%Benchmark High Share Repurchase INEXPENSIVECompanies with HighShare RepurchaseNote: valuation factor used to determine inexpensive companies is FCF/PSource: FactSet,, BofA Merrill Lynch US Equity & US Quant StrategyExhibit 1: BofAML Global Fund Manager Survey (January 2017): Whatwould you most like to see companies do with cash flow?Chart 9: Net Debt/EBITDA for the S&P 500 ex Financials (and excludingEnergy and Tech)3.53.02.52.01.5Source: BofA Merrill Lynch Global Fund Manager Survey (17 January 2017)1.086 88 90 92 94 96 98 00 02 04 06 08 10 12 14 16S&P 500 ex FinancialsS&P 500 ex Fins. & EnergyAvg.S&P 500 ex Fins. & TechSource: FactSet, BofA Merrill Lynch US Equity & US Quant StrategyPotential EPS impacts$8-9 (6-7%) hit to GAAP EPS from the mandatory tax on accumulated overseasprofitWe estimate that a tax of accumulated overseas profits of $1.2tn would result in a cashtax impact of $100-120bn (which may be allowed to be paid over 8-10 years), and aone-time hit to GAAP EPS of $8-9 (a lower $65-80bn, given that a several largemultinationals such as AAPL already provision for US taxes on a portion of theiroverseas profit, resulting in effective US tax rates well above the US statutory rate). Ouranalysis assumes Trump’s/the Blueprint’s proposed rates of 8.75%/10%, and that alloverseas profits are hit with this one-time tax, as suggested by their plans. See Table10.Note that our estimate of ~$1.2tn of cumulative profits overseas is based on estimatesfrom us, our fundamental analysts, and company filings, where in many cases onlyoverseas cash but not other indefinitely invested earnings are disclosed/estimated.Thus, the tax on these earnings could be slightly higher, though the Blueprint would taxearnings not held in cash at a lower 3.5% rate. (We conservatively assume our estimated$1.2tn is all cash and use the higher 8.75% rate under the Blueprint and 10% underTrump’s plan in our below analysis).10 Equity Strategy Focus Point | 29 January 2017Table 10: Tax impact from taxation of accumulated overseas profits at 10%/8.75% rates (assumingmandatory tax i.e. all overseas profits are taxed)Cash tax impact ($bn) One-time tax hit to GAAP earningsSector Trump (10%) Blueprint (8.75%) Trump (10%) Blueprint (8.75%)Consumer Discretionary 7.5 6.5 7.5 6.5Consumer Staples 6.8 5.9 6.8 5.9Energy 3.9 3.4 3.9 3.4Health Care 18.7 16.4 18.7 16.4Industrials 12.7 11.1 12.7 11.1Information Technology 64.7 56.6 26.0 22.7Materials 2.4 2.1 2.4 2.1Telecommunication Services 0.1 0.1 0.1 0.1Utilities 0.2 0.2 0.2 0.2S&P 500 ex. Financials & Real Estate 117.0 102.4 78.3 68.5S&P 500 GAAP EPS impact ($9) ($8)Source: FactSet, Bloomberg, BofAML Global Research estimates, BofA Merrill Lynch US Equity & US Quant StrategyWe estimate share buybacks add $4 (or as high as $6) to EPS (GAAP & non-GAAP)If the full $1.2tn that we estimate for overseas cash for the S&P 500 ex. Financials &Real Estate is brought back (given the tax is mandatory and will be paid either way) and50% is used on buybacks (~3% of S&P 500 market cap), this could add ~$4 to S&P 500EPS. And if 80% (~4% of market cap) were used on buybacks, similar to NBER’sestimate of what occurred following the 2004 tax holiday, this could add $6 to EPS.(The difference between the Trump and Blueprint tax rates is small, leading to onlycents in index EPS.) If one assumed companies only brought half of their offshore cashhome immediately, even though the full amount was taxed, these benefits would be cutin half.Note that buyback programs may span several years, which could spread out some ofthe EPS benefit below. But if one assumes a buyback is fully executed in Year 1, thisprovides a one-time boost to EPS growth and a recurring benefit to future EPS given apermanently lower share count.Table 11: Impact to S&P 500 EPS based on various buyback scenarios% used for buybacks: 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%Trump (10% tax) 1% 1% 2% 2% 3% 3% 4% 4% 5% 6%Blueprint (8.75% tax) 1% 1% 2% 2% 3% 3% 4% 5% 5% 6%Benefit to 2017 EPS: $1 $1 $2 $3 $4 $4 $5 $6 $7 $7Benefit to 2018 EPS: $1 $1 $2 $3 $4 $5 $5 $6 $7 $8Assumes 100% of overseas cash is brought back (given tax is mandatory)Source: FactSet, Bloomberg, BofA Merrill Lynch Global Research estimates, BofA Merrill Lynch US Equity & US Quant StrategyBelow we calculate the potential impact to sectors’ EPS under various buybackscenarios. Differences are small under the Trump vs. Blueprint tax rates.Table 12: Impact to sector EPS from various buyback scenarios underTrump (10% tax rate)% used for buybacks:10% 20% 30% 40% 50% 60% 70% 80% 90% 100%Cons. Disc. 0% 1% 1% 1% 1% 2% 2% 2% 3% 3%Staples 0% 1% 1% 1% 2% 2% 2% 3% 3% 3%Energy 0% 0% 1% 1% 1% 1% 2% 2% 2% 2%Health Care 1% 1% 2% 3% 3% 4% 5% 5% 6% 7%Industrials 1% 1% 2% 2% 3% 4% 4% 5% 5% 6%Tech 1% 3% 4% 6% 7% 9% 11% 13% 14% 16%Materials 0% 1% 1% 2% 2% 2% 3% 3% 4% 4%Telecom 0% 0% 0% 0% 0% 0% 0% 0% 0% 0%Utilities 0% 0% 0% 0% 0% 0% 0% 0% 0% 0%Assumes 100% of overseas cash is brought back (given tax is mandatory)Source: FactSet, Bloomberg, BofA Merrill Lynch Global Research estimates, BofA Merrill Lynch USEquity & US Quant StrategyTable 13: Impact to sector EPS from various buyback scenarios underBlueprint (8.75% tax rate)% used for buybacks:10% 20% 30% 40% 50% 60% 70% 80% 90% 100%Cons. Disc. 0% 1% 1% 1% 1% 2% 2% 2% 3% 3%Staples 0% 1% 1% 1% 2% 2% 2% 3% 3% 3%Energy 0% 0% 1% 1% 1% 1% 2% 2% 2% 3%Health Care 1% 1% 2% 3% 3% 4% 5% 5% 6% 7%Industrials 1% 1% 2% 2% 3% 4% 4% 5% 5% 6%Tech 1% 3% 4% 6% 8% 9% 11% 13% 15% 16%Materials 0% 1% 1% 2% 2% 2% 3% 3% 4% 4%Telecom 0% 0% 0% 0% 0% 0% 0% 0% 0% 0%Utilities 0% 0% 0% 0% 0% 0% 0% 0% 0% 0%Assumes 100% of overseas cash is brought back (given tax is mandatory)Source: FactSet, Bloomberg, BofA Merrill Lynch Global Research estimates, BofA Merrill Lynch USEquity & US Quant StrategyEquity Strategy Focus Point | 29 January 2017 11Cross-asset implications of repatriationRepatriation should spur USD-buying – up to 40% may be non-USD denominatedWhile few companies disclose the currency composition of their offshore cash, our FXteam estimates that 60-75% is already in USD while 25-40% is non-dollar-denominated.(If we extrapolate based on the S&P 500’s geographic revenue exposure, the largestproportion could be in Europe, followed by emerging Asia.) This may result in upwardpressure on the USD (which they estimate could amount to $250-$400bn if half of alloffshore cash, which they estimate at ~$2tn, was repatriated). Their analysis of theEUR-USD during the last repatriation holiday suggests an “announcement effect” islikely, as the dollar strengthened ahead of the bulk of the actual repatriation flows.Repatriation could put upward pressure on bank funding costsOur rates team’s analysis of some of the largest multinationals with offshore cashsuggests ~70% of cash is invested in securities with maturities greater than one year,with the remaining 30% having shorter maturities. See table below. They believerepatriation could put upward pressure on bank funding costs as firms reduce theirholdings in these short-term investments. According to Crane Data on offshore moneyfund holdings, our rates team cites that $161bn of offshore funds are held in commercialpaper and CDs, of which the majority are from financial institutions with Japan, France andCanada the largest issuers.Table 14: Offshore holdings and investment allocation for select firms(see footnote) per BofAML Rates team (as published 12/9/2016)Allocation*Cash & MMF 8%CP & CD 5%Tsy & Agy 35%Corporate 36%Non-US Sov 4%Other 12%Maturity of securities holdings**<1y 28%1-5y 59%5-10y 7%>10y 6%*Allocation = weighted avg of holdings across all company investments for AAPL, MSFT, CSCO, ORCL,GOOG, MRK, INTC and PFE. **Maturities = weighted avg. of holdings from MSFT, CSCO, GOOG, INTC.Source: BofAML Global Research, company 10Q’sExhibit 2: Offshore money fund USD asset holdings ($bn) as of 9/30/16Source: Crane data, BofA Merrill Lynch Global ResearchPotential beneficiaries: See Table 20 for a screen of companies with high (>10%)overseas cash to market capitalization ratios which could potentially benefit fromrepatriation.Border adjustment tax analysisA new tax policy outlined in the Blueprint proposal that has been getting a lot ofattention recently is the border adjustment tax, or the application of border adjustmentsto a company’s imports and exports. While Trump has described the proposal as being“too complicated,” it is a key component of the Blueprint plan and should not beignored. Additionally, White House press secretary Sean Spicer’s recent reference to“…the plan taking shape right now, using comprehensive tax reform as a means to taximports from countries…” could be a sign that Trump is not as against the proposal hisother comments would indicate.12 Equity Strategy Focus Point | 29 January 2017This policy would effectively result in the tax authorities recognizing all sales that takeplace in the US (regardless of where they are produced) and all the domestic costsincurred to produce goods and services for customers (regardless of where the saletakes place). As a result, net importers (such as many retailers) would suffer, as theywould have to pay taxes on their domestic sales without being able to deduct asignificant portion of their costs of production. Conversely, net exporters (companieswith much of their production in the US but sales outside of the US) would stand tobenefit from not having to pay taxes on their foreign sales while being able to deduct asignificant proportion of production costs (Exhibit 3). Purely domestic companies wouldbe unaffected.Exhibit 3: Illustration of border adjustment treatment of US corporate taxationUSSold in the US:Recognize salesMade in the US:Deduct costsSold overseas:Ignore salesNon-USSold overseas:Ignore salesMade in the US:Deduct costsSold in the US:Recognize salesMade overseas:Made overseas: Can’t deduct costsCan’t deduct costsSource: BofA Merrill Lynch US Equity & US Quant StrategyEven if border adjustments are enacted, there is significant uncertainty aroundimplementation details. For this analysis, we focus on the first order impact of borderadjustments, but we recognize there would be significant second order impacts on thepricing of products, pricing within the supply chain, foreign exchange rates as well asforeign policy reactions. (We discuss many of these second order impacts later in thisreport.) For the current exercise, we also ignored the cost of services as theimplementation of these rules would be more complicated. See the Methodologysection for more details.We estimate that at a 20% tax rate, border adjustments would detract $5-6 from 2018EPS, with nearly 80% of the drag coming from the Consumer Discretionary andConsumer Staples sectors (roughly evenly split). This impact includes a 50% haircut toaccount for offsets from alternate sourcing, currency rates and pricing power. On onehand, we may be drastically underestimating the impact because we have not includedthe second order impacts on the supply chain. For example, many retailers source thebulk of their goods from domestic suppliers, who source their goods from overseassuppliers. So while the original retailer may not feel the direct tax hit from importinggoods, the supplier that took the tax hit would likely pass along a significant portion ofthis via a higher cost. On the other hand, the supplier or the retailer could look foralternate domestic sources for those products, but it would largely depend on whetherthe cost differential of production between the US and overseas exceeded the borderadjustment tax. Some key components in determining the cost differential are theforeign exchange rates (more on this below) and labor costs. In the end, the net impactof the border adjustment taxes will be driven by a complex interplay between corporatetax rates, pricing power, foreign exchange moves, foreign versus domestic availabilityand cost differentials.Equity Strategy Focus Point | 29 January 2017 13Chart 10: Sector EPS impact from borderadjustment tax (15% rate)Staples -23%Discretionary -21%Energy-8%Health Care-4%Info Tech-3%Utilities0%Telecom0%Financials0%Real Estate0%Industrials1%Materials3%-30% -20% -10% 0% 10%15% tax rateSource: BofAML US Equity & Quant Strategy, FactSet, S&PChart 11: Sector EPS impact from borderadjustment tax (20% rate)Staples -31%Discretionary -28%Energy-10%Health Care-5%Info Tech-4%Utilities0%Telecom0%Financials0%Real Estate0%Industrials1%Materials4%-40% -30% -20% -10% 0% 10%20% tax rateSource: BofAML US Equity & Quant Strategy, FactSet, S&PChart 12: Sector EPS impact from borderadjustment tax (25% rate)Staples -38%Discretionary -35%Energy-13%Health Care-6%Info Tech-5%Utilities0%Telecom0%Financials0%Real Estate0%Industrials2%Materials5%-50% -40% -30% -20% -10% 0% 10%25% tax rateSource: BofAML US Equity & Quant Strategy, FactSet, S&POffsetting BAT with a little math and some price increasesA company could fully offset the border adjustment tax by raising prices such that theafter-tax increase in sales would exceed the drag from the lost deduction of costs. Allelse equal, the break-even price increase would be equivalent to the cost of goods soldas a % of sales multiplied by net % imported and the tax to after-tax ratio, which at a20% rate is 0.25 (20%/80%).As an example, a company with a 25% gross margin that imports 30% of its goodswould need to increase its prices by of 5-6% to offset the border adjustment tax, allelse equal.Offsetting BAT with FXSome of the increase in the after-tax cost of imported goods can also be offset by astrengthening dollar. For example, companies producing goods in Mexico, which stand tosee a 25% increase in the cost of imported goods, should see the cost increase partiallyoffset by the 13% devaluation of the Mexican Peso against the US dollar since theelection. The net cost increase is a more digestible 9%, especially when you alsoconsider that the Peso has devalued nearly 30% since its 2013 peak. While it may offerlittle consolation to corporates, the US Dollar Index is up over 25% since mid-2014, sothe border adjustment tax would presumably act as a reversal of the lowered cost ofoverseas production over that period.Border adjustment sensitivity analysisThe table below illustrates how the change in the tax rate and the application of theborder adjustment tax would impact the domestic earnings of a hypothetical companywith sensitivity to different tax rates and net export assumptions. We assumed thecompany has a 40% gross margin, operating expenses are 20% of sales and an initialtax rate of 35%. As you would expect, the biggest benefit would accrue to companieswith significant net exports at a high domestic tax rate (bigger tax shield) and the mostnegative impact to significant net imports at a high domestic tax rate (higher taxes onhigher taxable income).14 Equity Strategy Focus Point | 29 January 2017Table 15: Sensitivity of a company’s domestic earningsNet exports (% of COGS)Tax rate -100% -50% 0% 50% 100%*15% -38% -4% 31% 65% 100%18% -54% -13% 27% 67% 108%20% -69% -23% 23% 69% 115%23% -85% -33% 19% 71% 123%25% -100% -42% 15% 73% 131%28% -115% -52% 12% 75% 138%30% -131% -62% 8% 77% 146%33% -146% -71% 4% 79% 154%35% -162% -81% 0% 81% 162%Source: BofAML US Equity & Quant Strategy*We note that it is unlikely that a company can be a 100% net exporter and have any domestic earnings to begin with.Note: We assume a company with a 40% gross margin, operating expenses are 20% of sales and an initial tax rate of 35%Industry screen: Below we highlight industries which could potentiallybenefit most / be hurt most by the BAT.Chart 13: Industry EPS impact from borderadjustment tax (15% rate)-100% -50% 0% 50%Industrial ConglomeratesLife Sciences Tools & SvcsChemicalsHousehold ProductsMachineryHealth Care TechnologyElectrical EquipmentMediaIT SvcsEnergy Equipment & SvcsBiotechnology-1%Semiconductors & Sem Equip-2%Software-2%Pharmaceuticals-2%Trading Cos & Distributors-3%Health Care Equipment &…-4%Metals & Mining-5%Building Products-5%Electronic Equip Instr &…-6%Construction Materials-6%Oil Gas & Consumable Fuels-9%Communications Equipment-9%Tech Hardware-9%Health Care Providers & Svcs-11%Household Durables-12%Auto Components-20%Leisure Products -30%Specialty Retail -33%Distributors -38%Textiles Apparel & Luxury Goods -39%Internet & Direct Mktg Retail -41%Automobiles -41%Multiline Retail -49%Food & Staples Retailing -74%5%4%4%3%3%2%2%2%1%1%Chart 14: Industry EPS impact from borderadjustment tax (20% rate)-150% -100% -50% 0% 50%Industrial ConglomeratesChemicalsLife Sciences Tools & SvcsHousehold ProductsMachineryHealth Care TechnologyElectrical EquipmentMediaIT SvcsEnergy Equipment & SvcsBiotechnology-1%Semiconductors & Sem Equip-2%Software-3%Pharmaceuticals-3%Trading Cos & Distributors-3%Health Care Equipment &…-5%Metals & Mining-7%Building Products-7%Electronic Equip Instr &…-8%Construction Materials-9%Oil Gas & Consumable Fuels-12%Tech Hardware-12%Communications Equipment-12%Health Care Providers & Svcs-14%Household Durables-16%Auto Components-21%Leisure Products-40%Specialty Retail-45%Distributors-51%Textiles Apparel & Luxury Goods-52%Internet & Direct Mktg Retail -54%Automobiles -55%Multiline Retail -65%Food & Staples Retailing -99%7%5%5%4%4%3%3%2%2%1%Chart 15: Industry EPS impact from borderadjustment tax (25% rate)Industrial ConglomeratesChemicalsLife Sciences Tools & SvcsMachineryHousehold ProductsHealth Care TechnologyElectrical EquipmentMediaIT SvcsEnergy Equipment & SvcsBiotechnologySemiconductors & Sem EquipSoftwarePharmaceuticalsTrading Cos & DistributorsHealth Care Equipment &…Electronic Equip Instr &…Metals & MiningBuilding ProductsConstruction MaterialsTech HardwareOil Gas & Consumable FuelsCommunications EquipmentHealth Care Providers & SvcsHousehold DurablesAuto ComponentsLeisure ProductsSpecialty RetailDistributorsTextiles Apparel & Luxury GoodsInternet & Direct Mktg RetailAutomobilesMultiline RetailFood & Staples Retailing-200% -150% -100% -50% 0% 50%-2%-3%-3%-4%-4%-6%-8%-9%-9%-11%-14%-15%-15%-18%-20%-21%-50%-56%-64%-65%-68%-69%-81%-124%8%6%6%5%5%4%4%3%2%2%15% tax rate20% tax rate25% tax rateSource: BofAML US Equity & Quant Strategy, FactSet, S&PSource: BofAML US Equity & Quant Strategy, FactSet, S&PSource: BofAML US Equity & Quant Strategy, FactSet, S&PClosing loopholesBoth Trump and the Blueprint proposal suggest getting rid of special-interestdeductions and credits that distort capital allocation decisions. The table below lists the25 biggest US corporate tax breaks. The #1 and #3 “tax breaks” are the deferral offoreign income and certain foreign financial income, but these would become irrelevantif the US moves to a territorial tax system, as is being proposed by the Blueprint plan.Exempting corporations from paying US taxes on foreign income would put the US inEquity Strategy Focus Point | 29 January 2017 15line with the rest of the world on this issue. Similarly, the accelerated depreciation ofmachinery & equipment would become irrelevant due to the move toward taxationbased on business cash flow and the immediate write-off of capital expenditures. Oncethe depreciation from legacy investments has run off, then depreciation should becomeirrelevant for tax purposes. We also highlight the deduction for US production activities(section 199) due to it being specifically highlighted by the Blueprint proposal as nolonger being necessary under the new tax policies. Both the Blueprint and Trump havenoted that they would likely maintain the Research & Development related tax credits.Table 16: Top 25 US corporate tax breaks (2016)Government tax expenseCategory/Industry2016($mn)Deferral of income from controlled foreign corporations International affairs 102,100Accelerated depreciation of machinery & equipment Commerce 28,570Deferred taxes for financial firms on certain income earned overseas International affairs 15,320Deduction for US production activities Commerce 12,080Credit for increasing research activities General science, space, and technology 9,580Exclusion of interest on public purpose State & local bonds General purpose fiscal assistance 8,400Credit for low-income housing investments Housing 8,200Expensing of research & experimentation expenditures General science, space, and technology 6,350Deferral of gains from like-kind exchanges Commerce 5,720Inventory property sales source rules exception International affairs 4,270Graduated corporation income tax rate Commerce 3,300Exemption of credit union income Financial institutions and insurance 2,310Special ESOP rules Income security 1,910Deductibility of charitable contributions, other than education & health Training, employment, and social services 1,720Tax credit for orphan drug research Health 1,700Exclusion & deferral of policyholder income earned on life insurance & annuity contracts Financial institutions and insurance 1,470New markets tax credit Community and regional development 1,260Energy production credit Energy 1,050Exclusion of interest on hospital construction bonds Health 1,010Energy investment credit Energy 890Work opportunity tax credit Training, employment, and social services 830Deductibility of charitable contributions (education) Education 820Tax exemption of insurance income earned by tax-exempt organizations Financial institutions and insurance 690Exclusion of interest on bonds for private nonprofit educational facilities Education 660Special Blue Cross/Blue Shield tax benefits Health 630Source: BofAML US Equity & Quant Strategy, US Department of TreasuryImmediate capex expensing should provide some initial cash tax benefitsThe shift to the immediate expensing of capital expenditures should provide asignificant near-term reduction in cash taxes as companies benefit from the ongoingreduction of taxable income from the depreciation of legacy assets combined with thefull expensing of new investments. As the depreciation of legacy assets rolls off, the taxbenefit would become more modest. Keep in mind that, for tax reporting, manycompanies already take advantage of the accelerated depreciation schedules discussedabove. The ongoing benefit of capex expensing derives from the deferral in the timingof tax payments.Chart 16: S&P 500 capital expenditure to depreciation & amortization ratio1.61.51.41.31.21.11.0'86 '87 '88 '89 '90 '91 '92 '93 '94 '95 '96 '97 '99 '00 '01 '02 '03 '04 '05 '06 '07 '08 '09 '10 '12 '13 '14 '15 '16Capex/D&AAvg.Source: BofAML US Equity & Quant Strategy, S&P, Compustat16 Equity Strategy Focus Point | 29 January 2017No interest tax shieldAnother key offset to the lower corporate tax rate is the proposed ending of thededuction of net interest expense. We assume that this rule would apply to new debtand that existing debt would be grandfathered. This tax shield removal would increasethe cost of debt by an incremental 25% (not to mention the 100bp+ rise in long-terminterest rates seen since the summer of 2016). In the table below, we illustrate theimpact on S&P 500 corporate profits. We estimate that over time, the removal of theinterest rate deduction would detract about 4%, or $4-5 from S&P 500 2018 EPS,although the initial impact would be less significant given 70-90% of the debt is longterm.Table 17: Estimated EPS impact from the removal of interest tax shieldS&P 500 Non-FinancialsNet Debt ($mn) 2,899Net Debt/EBITDA 1.74New tax rate 20%After-tax interest rate [interest rate w/ no tax shield * (1 - new tax rate)] 4.2%Interest rate w/ no tax shield [interest expense / net debt] 5.2%Change in cost of debt [(interest rate w/ no tax shield / after-tax interest rate) -1] 25%Potential profit impact (%) [(interest rate w/) no tax shield - after-tax interest rate) * (net debt / net income)] 4%Potential impact on 2018 EPS $4-5Source: BofAML US Equity & US Quant Strategy, S&P, FactSetMany investors assume that interest deductions would likely apply only to new debt, andif this were the case, the drag would be gradual for the overall S&P 500 as debt maturesand is refinanced. Companies have shifted the composition of their debt toward longermaturities and fixed rates. We estimate an average S&P 500 debt maturity of over eightyears, with just one-third maturing within the next three years. The grandfathering ofexisting debt is a reasonable assumption, but not a sure thing, in our view. There is apossibility that legislators apply it to all debt on the grounds that most companies areexpected to be net beneficiaries of comprehensive tax reform.There is also a possibility that this policy is phased in over a number of years, withcertain portions of the existing debt losing their interest deductibility over time.Chart 17: Russell 1000 debt by type andmaturity - 2007STFloating,23.3%LTFloating,19.7%STFixed,2.8%Source: FactSet, BofAML US Equity & US Quant StrategyLTFixed,54.2%Chart 18: Russell 1000 debt by type andmaturity - October 2016STFloating,15.3%LTFloating,14.0%STFixed,4.1%LTFixed,66.6%Source: FactSet, BofAML US Equity & US Quant StrategyTable 18: Russell 1000 estimated weightedaverage debt maturity (ex-Financials & REITs)Sector Estimated Wtd Avg Maturity (years)Cons. Disc. 7.0Cons. Staples 8.1Energy 8.4Health Care 8.0Industrials 8.0Materials 7.4Technology 7.4Telecom 10.8Utilities 12.0Total 8.3Source: FactSet, BofAML US Equity & US Quant StrategyThe most negatively impacted companies would clearly be the ones with the mostleverage, in addition to those with depressed earnings (Metals & Mining, Energy, etc.).While the Utilities sector has a lot of leverage, there would likely be a pass through tocustomers in determining their allowed rate increase.Equity Strategy Focus Point | 29 January 2017 17Chart 19: Sector EPS impact from endinginterest deductibility (15% rate; ex- fin, utes)Energy -6.2%Telecom -5.9%MaterialsDiscretionaryIndustrialsReal EstateStaplesHealth CareInfo Tech-8% -6% -4% -2% 0%-3.5%-3.1%-2.7%-2.8%-2.2%-1.7%-0.9%Chart 20: Sector EPS impact from endinginterest deductibility (20% rate; ex- fin, utes)EnergyTelecomMaterialsDiscretionaryIndustrialsReal EstateStaplesHealth CareInfo Tech-12%-10%-8% -6% -4% -2% 0%-8.2%-7.9%-4.7%-4.1%-3.5%-3.4%-2.9%-2.3%-1.1%Chart 21: Sector EPS impact from endinginterest deductibility (25% rate; ex- fin, utes)EnergyTelecomMaterialsDiscretionaryIndustrialsReal EstateStaplesHealth CareInfo Tech-15% -10% -5% 0%-10.2%-9.6%-5.7%-5.1%-4.3%-3.8%-3.6%-2.7%-1.3%15% tax rateSource: BofAML US Equity & Quant Strategy, FactSet, S&P20% tax rateSource: BofAML US Equity & Quant Strategy, FactSet, S&P25% tax rateSource: BofAML US Equity & Quant Strategy, FactSet, S&PHow will levered companies react?Companies will likely grow comfortable with a smaller amount of debt, retain moreearnings, use less cash for dividends and share buybacks, and potentially draw downcash if they have it. If a tax holiday is also granted, that might offset the loss of benefit.Companies that regularly issue long-term debt may choose to reduce that burden tooffset the tax change, and find those funds elsewhere. We find it unlikely that thechange would result in a surge in equity issuance, unless the change applies to existingdebt, which is unlikely in our view. While this change should be taken as a line item in awholistic bill, there are victims and beneficiaries here. Corporations that have highleverage ratios, low retained earnings, high interest expense to earnings ratios, no cashoverseas offset from repatriation, and those that have recurring long-term debt needsmay be most at risk.Other implicationsWhile some argue that companies will try to raise outsized amounts of investment gradecapital ahead of the deadline to lock in funding with the tax benefit before the loopholeis closed, there is a reasonable chance that a provision is included in the legislation thatwould treat such debt as new debt. In our Investment Grade Strategist Hans Mikkelsen’sview, demand for IG credit could be materially reduced over time. The tax change couldalso dampen Leverage Buyout (LBO) activity, according to our High Yield strategistMichael Contopoulos, where these funds are already struggling to generate high returns– note that LBO funds are currently sitting on close to $1tn in cash looking for a home,according to Preqin’s third quarter update.Who could be hurt: See Table 21 for a screen of stocks with high net interestexpense as a percentage of net income which could potentially be hurt most by anend to the deductibility of interest expense.18 Equity Strategy Focus Point | 29 January 2017Tax reform screensLower US corporate tax rate: potential beneficiariesBelow we provide a screen of domestically-oriented S&P 500 companies (<10% foreignsales exposure) with a high (>35%) median 5-year effective tax rate which couldpotentially benefit most from a lower US corporate tax rate.Table 19: S&P 500 companies with high (>35%) median 5-year effective tax rates and low (<10%) foreign salesTicker Company Name Sector IndustryForeign Sales%5-Year Median Effective TaxRate %CHTR Charter Communications, Inc. Class A Consumer Discretionary Media 0% 445.3DVN Devon Energy Corporation Energy Oil Gas & Consumable Fuels 8% 58.3REGN Regeneron Pharmaceuticals, Inc. Health Care Biotechnology 0% 44.3COG Cabot Oil & Gas Corporation Energy Oil Gas & Consumable Fuels 0% 43.5EOG EOG Resources, Inc. Energy Oil Gas & Consumable Fuels 5% 42.3RRC Range Resources Corporation Energy Oil Gas & Consumable Fuels 0% 41.9CNC Centene Corporation Health Care Health Care Providers & Services 0% 41.4ABC AmerisourceBergen Corporation Health Care Health Care Providers & Services 0% 40.2CNP CenterPoint Energy, Inc. Utilities Multi-Utilities 0% 39.7AWK American Water Works Company, Inc. Utilities Water Utilities 0% 39.4SWN Southwestern Energy Company Energy Oil Gas & Consumable Fuels 0% 39.3CVS CVS Health Corporation Consumer Staples Food & Staples Retailing 0% 39.3WFM Whole Foods Market, Inc. Consumer Staples Food & Staples Retailing 3% 38.7CMG Chipotle Mexican Grill, Inc. Consumer Discretionary Hotels Restaurants & Leisure 1% 38.5JWN Nordstrom, Inc. Consumer Discretionary Multiline Retail 0% 38.5AN AutoNation, Inc. Consumer Discretionary Specialty Retail 0% 38.5TROW T. Rowe Price Group Financials Capital Markets 0% 38.4KMX CarMax, Inc. Consumer Discretionary Specialty Retail 0% 38.2PEG Public Service Enterprise Group Inc Utilities Multi-Utilities 0% 38.2JBHT J.B. Hunt Transport Services, Inc. Industrials Road & Rail 0% 38.1ULTA Ulta Salon, Cosmetics & Fragrance, Inc. Consumer Discretionary Specialty Retail 0% 38.1CHK Chesapeake Energy Corporation Energy Oil Gas & Consumable Fuels 0% 38.0AEE Ameren Corporation Utilities Multi-Utilities 0% 37.9ALK Alaska Air Group, Inc. Industrials Airlines 0% 37.9CTL CenturyLink, Inc. Telecommunication Services Diversified Telecommunication Services 0% 37.8UNP Union Pacific Corporation Industrials Road & Rail 0% 37.7ROST Ross Stores, Inc. Consumer Discretionary Specialty Retail 0% 37.7LOW Lowe's Companies, Inc. Consumer Discretionary Specialty Retail 8% 37.6BBY Best Buy Co., Inc. Consumer Discretionary Specialty Retail 8% 37.5AAP Advance Auto Parts, Inc. Consumer Discretionary Specialty Retail 0% 37.5LUV Southwest Airlines Co. Industrials Airlines 0% 37.4SYF Synchrony Financial Financials Consumer Finance 0% 37.2DLTR Dollar Tree, Inc. Consumer Discretionary Multiline Retail 8% 37.2SCHW Charles Schwab Corporation Financials Capital Markets 0% 37.2NAVI Navient Corp Financials Consumer Finance 0% 37.2CAH Cardinal Health, Inc. Health Care Health Care Providers & Services 4% 37.1CXO Concho Resources Inc. Energy Oil Gas & Consumable Fuels 0% 37.1DFS Discover Financial Services Financials Consumer Finance 0% 37.1DGX Quest Diagnostics Incorporated Health Care Health Care Providers & Services 2% 37.1CSRA CSRA, Inc. Information Technology IT Services 0% 37.1DG Dollar General Corporation Consumer Discretionary Multiline Retail 0% 37.0XEC Cimarex Energy Co. Energy Oil Gas & Consumable Fuels 0% 37.0WEC WEC Energy Group Inc Utilities Multi-Utilities 0% 36.9CSX CSX Corporation Industrials Road & Rail 0% 36.9CTAS Cintas Corporation Industrials Commercial Services & Supplies 9% 36.9ORLY O'Reilly Automotive, Inc. Consumer Discretionary Specialty Retail 0% 36.7KSS Kohl's Corporation Consumer Discretionary Multiline Retail 0% 36.7BBBY Bed Bath & Beyond Inc. Consumer Discretionary Specialty Retail 0% 36.6TSCO Tractor Supply Company Consumer Discretionary Specialty Retail 0% 36.6HUM Humana Inc. Health Care Health Care Providers & Services 0% 36.5TSO Tesoro Corporation Energy Oil Gas & Consumable Fuels 0% 36.5ESRX Express Scripts Holding Company Health Care Health Care Providers & Services 0% 36.4HD Home Depot, Inc. Consumer Discretionary Specialty Retail 9% 36.4CME CME Group Inc. Class A Financials Capital Markets 0% 36.4UNH UnitedHealth Group Incorporated Health Care Health Care Providers & Services 4% 36.4PAYX Paychex, Inc. Information Technology IT Services 1% 36.3NSC Norfolk Southern Corporation Industrials Road & Rail 0% 36.2M Macy's Inc Consumer Discretionary Multiline Retail 0% 36.2RAI Reynolds American Inc. Consumer Staples Tobacco 5% 36.1CMCSA Comcast Corporation Class A Consumer Discretionary Media 8% 35.8AZO AutoZone, Inc. Consumer Discretionary Specialty Retail 6% 35.7UHS Universal Health Services, Inc. Class B Health Care Health Care Providers & Services 0% 35.5AET Aetna Inc. Health Care Health Care Providers & Services 2% 35.5DVA DaVita Inc. Health Care Health Care Providers & Services 0% 35.4Equity Strategy Focus Point | 29 January 2017 19Table 19: S&P 500 companies with high (>35%) median 5-year effective tax rates and low (<10%) foreign salesTicker Company Name Sector IndustryForeign Sales%5-Year Median Effective TaxRate %FE FirstEnergy Corp. Utilities Electric Utilities 0% 35.3ZION Zions Bancorporation Financials Banks 0% 35.2MO Altria Group, Inc. Consumer Staples Tobacco 0% 35.1EXC Exelon Corporation Utilities Electric Utilities 0% 35.1RSG Republic Services, Inc. Industrials Commercial Services & Supplies 0% 35.0Note: This screen is not a recommended list either individually or as a group of stocks. Investors should consider the fundamentals of the companies and their own individual circumstances/objective before making anyinvestment decisions.Source: FactSet, BofA Merrill Lynch US Equity & US Quant StrategyRepatriation: potential beneficiariesBelow we provide a screen of S&P 500 companies (excluding Financials and Real Estate)with high (>10%) overseas cash as a percent of market cap, which could potentiallybenefit most from repatriation.Table 20: S&P 500 (ex. Financials & Real Estate) companies with the highest overseas cash* as a % of their market cap (>10%)Ticker Company Sector Industry Overseas Cash ($mn) Overseas Cash as a % of Mkt CapWU Western Union Company Information Technology IT Services 6,100 62%FSLR First Solar, Inc. Information Technology Semiconductors & Semiconductor 1,500 59%NWS News Corporation Class B Consumer Discretionary Media 813 54%ORCL Oracle Corporation Information Technology Software 48,200 40%CSCO Cisco Systems, Inc. Information Technology Communications Equipment 59,800 39%NTAP NetApp, Inc. Information Technology Technology Hardware, Storage & 4,000 39%QCOM QUALCOMM Incorporated Information Technology Semiconductors & Semiconductor 29,600 36%AAPL Apple Inc. Information Technology Technology Hardware, Storage & 216,000 34%JNPR Juniper Networks, Inc. Information Technology Communications Equipment 3,167 30%SYMC Symantec Corporation Information Technology Software 4,900 29%PVH PVH Corp. Consumer Discretionary Textiles, Apparel & Luxury Goo 2,100 28%AMGN Amgen Inc. Health Care Biotechnology 29,000 26%GE General Electric Company Industrials Industrial Conglomerates 64,680 24%MSFT Microsoft Corporation Information Technology Software 108,900 22%TDC Teradata Corporation Information Technology IT Services 819 22%CTSH Cognizant Technology Solutions Corp. Class A Information Technology IT Services 7,495 22%RL Ralph Lauren Corporation Class A Consumer Discretionary Textiles, Apparel & Luxury Goo 1,085 21%CA CA, Inc. Information Technology Software 2,137 21%WAT Waters Corporation Health Care Life Sciences Tools & Services 2,346 20%LRCX Lam Research Corporation Information Technology Semiconductors & Semiconductor 3,500 19%NWSA News Corporation Class A Consumer Discretionary Media 813 18%GOOG Alphabet Inc. Class C Information Technology Internet Software & Services 42,900 18%MCHP Microchip Technology Incorporated Information Technology Semiconductors & Semiconductor 2,559 17%GOOGL Alphabet Inc. Class A Information Technology Internet Software & Services 42,900 17%GILD Gilead Sciences, Inc. Health Care Biotechnology 15,700 17%VRSN VeriSign, Inc. Information Technology Internet Software & Services 1,200 16%PBI Pitney Bowes Inc. Industrials Commercial Services & Supplies 470 16%XLNX Xilinx, Inc. Information Technology Semiconductors & Semiconductor 2,240 15%ADI Analog Devices, Inc. Information Technology Semiconductors & Semiconductor 3,374 15%A Agilent Technologies, Inc. Health Care Life Sciences Tools & Services 2,181 14%NOV National Oilwell Varco, Inc. Energy Energy Equipment & Services 2,034 14%CTXS Citrix Systems, Inc. Information Technology Software 1,970 13%KLAC KLA-Tencor Corporation Information Technology Semiconductors & Semiconductor 1,730 13%GPS Gap, Inc. Consumer Discretionary Specialty Retail 685 13%WDC Western Digital Corporation Information Technology Technology Hardware, Storage & 2,800 13%GT Goodyear Tire & Rubber Company Consumer Discretionary Auto Components 1,042 13%ADSK Autodesk, Inc. Information Technology Software 2,059 13%PCLN Priceline Group Inc Consumer Discretionary Internet & Direct Marketing Re 9,800 13%JNJ Johnson & Johnson Health Care Pharmaceuticals 38,200 13%MRK Merck & Co., Inc. Health Care Pharmaceuticals 20,995 12%GLW Corning Inc Information Technology Electronic Equip., Instruments 3,085 12%MJN Mead Johnson Nutrition Company Consumer Staples Food Products 1,577 11%LLY Eli Lilly and Company Health Care Pharmaceuticals 8,100 11%KO Coca-Cola Company Consumer Staples Beverages 17,900 11%MOS Mosaic Company Materials Chemicals 1,276 11%AMAT Applied Materials, Inc. Information Technology Semiconductors & Semiconductor 4,000 11%PH Parker-Hannifin Corporation Industrials Machinery 2,065 11%*For some companies, total overseas cash may represent total accumulated overseas profits. Overseas cash based on BofAML analyst estimates or Bloomberg data from company disclosures.Note: This screen is not a recommended list either individually or as a group of stocks. Investors should consider the fundamentals of the companies and their own individual circumstances/objective before making anyinvestment decisions.Source: FactSet, Bloomberg, BofA Merrill Lynch Global research estimates, BofA Merrill Lynch US Equity & US Quant Strategy20 Equity Strategy Focus Point | 29 January 2017End of interest deductibility: who could be hurt?Below we provide a screen of the top 50 S&P 500 companies (excluding Financials, RealEstate and Utilities) by high net interest expense as a percentage of net income, whichcould potentially be hurt by an end to the deductibility of interest expense.Table 21: S&P 500 (ex. Financials, Real Estate & Utilities) with high net interest expense as a % of net incomeTicker Company Sector Industry Net Interest Expense (% of L12M Net Income)CHTR Charter Communications, Inc. Class A Consumer Discretionary Media 1387%DVN Devon Energy Corporation Energy Oil, Gas & Consumable Fuels 467%CXO Concho Resources Inc. Energy Oil, Gas & Consumable Fuels 357%MU Micron Technology, Inc. Information Technology Semiconductors & Semiconductor 316%FCX Freeport-McMoRan, Inc. Materials Metals & Mining 280%OKE ONEOK, Inc. Energy Oil, Gas & Consumable Fuels 135%KMI Kinder Morgan Inc Class P Energy Oil, Gas & Consumable Fuels 120%LVLT Level 3 Communications, Inc. Telecommunication Services Diversified Telecommunication 96%WYNN Wynn Resorts, Limited Consumer Discretionary Hotels Restaurants & Leisure 95%CTL CenturyLink, Inc. Telecommunication Services Diversified Telecommunication 94%CF CF Industries Holdings, Inc. Materials Chemicals 92%NFX Newfield Exploration Company Energy Oil, Gas & Consumable Fuels 82%RIG Transocean Ltd. Energy Energy Equipment & Services 81%NFLX Netflix, Inc. Consumer Discretionary Internet & Direct Marketing Re 80%SE Spectra Energy Corp Energy Oil, Gas & Consumable Fuels 78%TDG TransDigm Group Incorporated Industrials Aerospace & Defense 77%HCA HCA Holdings, Inc. Health Care Health Care Providers & Servic 63%MPC Marathon Petroleum Corporation Energy Oil, Gas & Consumable Fuels 56%CAT Caterpillar Inc. Industrials Machinery 56%EVHC Envision Healthcare Corp. Health Care Health Care Providers & Servic 55%URI United Rentals, Inc. Industrials Trading Companies & Distributo 54%DVA DaVita Inc. Health Care Health Care Providers & Servic 52%TGNA TEGNA, Inc. Consumer Discretionary Media 52%DE Deere & Company Industrials Machinery 50%MAS Masco Corporation Industrials Building Products 49%ENDP Endo International Plc Health Care Pharmaceuticals 48%COTY Coty Inc. Class A Consumer Staples Personal Products 47%IP International Paper Company Materials Containers & Packaging 47%R Ryder System, Inc. Industrials Road & Rail 46%DLTR Dollar Tree, Inc. Consumer Discretionary Multiline Retail 46%NEM Newmont Mining Corporation Materials Metals & Mining 46%FOX Twenty-First Century Fox, Inc. Class B Consumer Discretionary Media 46%GT Goodyear Tire & Rubber Company Consumer Discretionary Auto Components 45%RSG Republic Services, Inc. Industrials Commercial Services & Supplies 45%SEE Sealed Air Corporation Materials Containers & Packaging 45%PBI Pitney Bowes Inc. Industrials Commercial Services & Supplies 45%AN AutoNation, Inc. Consumer Discretionary Specialty Retail 44%KSS Kohl's Corporation Consumer Discretionary Multiline Retail 44%F Ford Motor Company Consumer Discretionary Automobiles 43%VIAB Viacom Inc. Class B Consumer Discretionary Media 42%MNK Mallinckrodt Plc Health Care Pharmaceuticals 41%ADS Alliance Data Systems Corporation Information Technology IT Services 41%WRK WestRock Co. Materials Containers & Packaging 40%VRTX Vertex Pharmaceuticals Incorporated Health Care Biotechnology 39%BLL Ball Corporation Materials Containers & Packaging 37%GE General Electric Company Industrials Industrial Conglomerates 37%M Macy's Inc Consumer Discretionary Multiline Retail 37%CVX Chevron Corporation Energy Oil, Gas & Consumable Fuels 37%SLB Schlumberger NV Energy Energy Equipment & Services 37%TSO Tesoro Corporation Energy Oil, Gas & Consumable Fuels 36%Note: This screen is not a recommended list either individually or as a group of stocks. Investors should consider the fundamentals of the companies and their own individual circumstances/objective before making anyinvestment decisions.Source: FactSet, BofaA Merrill Lynch US Equity & US Quant StrategyEquity Strategy Focus Point | 29 January 2017 21Related BofAML research on US tax reformBelow we provide links to reports from our BofAML Global Research colleagues thataddress this topic.Economics:Global Watch: Will border adjustment lead to border battles? 18 January 2017US Economic Weekly: Cutting taxes could be taxing 02 December 2016Credit strategy:Situation Room: Corporate tax reform=less debt 28 November 2016The HY Wire: ‘A Better Way’: tax proposals could affect HY issuance 09 December 2016FX:FX Watch: Ten thoughts on Border Adjustments 18 January 2017FX Viewpoint: Homeland Investment redux? 17 October 2016Autos:Automotive Industry: The Trump trade – implications for the automotive value chain 18January 2017Consumer/Retail:Retailing - Hardlines: A taxing set of proposals for Hardline Retailers 14 December 2016Specialty Retail and Department Stores: Border adjustment seems unlikely but woulddecimate retail earnings 14 December 2016US Consumer Staples: Policy changes: what to watch for 18 January 2017Cosmetics, Household & Personal Care: 2017 – The Year Ahead: a few diamonds in therough 10 January 2017Consumer Staples: 2017 - the year ahead: sector rotation puts fundamentals in focus 13December 2016Tobacco: Tobacco Year Ahead 2017; see domestic players having more upside potentialthis yr 04 January 2017Homebuilders and Building Products: State of the union 12 December 2016Financials / Real Estate:2017 Banks Year Ahead: T-R-U-M-P: Find out what it means for “E” (20% potentialupside) 10 January 2017US Banks Chart of the Week: Muni exposure will mute benefit from lower corporatetaxes 11 December 2016Insurance: Tax changes could have mixed implications 18 January 2017Brokers, Asset Managers & Exchanges: 2017 Year Ahead: An attractive outlook, with 12-20%+ upside, with catalysts 12 January 2017U.S. REITs: Regulatory changes are coming: A REIT analyst guidebook 17 January 2017Health Care:Managed Care: MCO rally has just begun; beneficiaries of the non-Health Care upsidefrom Trump 02 December 2016Biotechnology: On the road to recovery 04 January 2017Healthcare: 2017 – the year ahead: the only constant is change 15 December 201622 Equity Strategy Focus Point | 29 January 2017Energy:Refiners: What’s going on with Refining in 2017: potential benefits in a Trumpadministration 05 January 2017Industrials / Materials:Industrials/Multi-Industry: DEM#217: The Year Ahead; Resetting for higher US growthand inflation 09 January 2017Engineering & Construction: 2017 view: energy backlog more 2H story, owninfrastructure & federal 12 January 2017Transportation - Railroads: 2017 Rail Year Ahead: Macro factors favor group; 1H compsset stage for growth 12 January 2017Business, Education & Professional Services: 2017 year ahead: INFO top pick inBusiness Services 12 January 2017Basic Materials & Industrials 2017 Year Ahead: Buy America and inflation, but watch theUS dollar and interest rates 12 December 2016Global Chemicals: Potential tax reform could be more meaningful than infrastructurespending 15 December 2016Tech:Apple Inc.: Deep Dive - Benefit from lower U.S. tax rate, but border tax could be onerous13 January 2017Server & Enterprise Software: Tax reform +ve for INTU, CRM; Cash repatriation +ve forORCL, MSFT, VMW 12 December 2016Semiconductor Capital Equipment: Tax sensitivity analysis. Repatriation a bigger dealthan taxes for Semicaps, EDA 02 December 2016Telecom Equipment: New administration appears likely to drive spending oninfrastructure & cyber security 18 January 2017Internet/e-Commerce: Top 2017 US Internet Sector Drivers – Trump Act One 17 January2017Telecom:Wireline & Wireless Telecom Services: For AT&T, Verizon and CenturyLink, the telco taxtrade could be ‘Huge’ 19 December 2016Wireline & Wireless Telecom Services: 2017 Year Ahead – Fiscal forces, regulation, andvideo migration to mobile 10 January 2017Media:Media & Entertainment: 2017 year ahead - living the stream 11 January 2017Cable/Satellite: 2017 year ahead – reform, relief and resilience 11 January 2017Utilities:Utilities: 2017 Year Ahead: Washington DC will likely cast a long shadow on utilities 06January 2017Equity Strategy Focus Point | 29 January 2017 23MethodologyRepatriation impactWe estimated cumulative overseas profits for the S&P 500 excluding Financials andReal Estate via three sources: 1) Bloomberg data on cash held overseas (ifdisclosed/available), 2) BofAML analyst estimates on cumulative overseas profits orcash, and 3) our own estimate if neither (1) or (2) are available, based on (Total cash x[% of foreign sales +10%]) for companies with at least 5% foreign sales.We apply the effective tax rates proposed by Trump (10%) and the Blueprint (8.75%) toour estimated $1.2tn in overseas cash to determine taxes due for the S&P 500 ex.Financials & Real Estate. We estimate that 100% is brought back given that the tax ismandatory. To compute the one-time tax impact to GAAP EPS, we divide the cumulativetax impact by the S&P 500 divisor, after first excluding the impact from several largemultinationals (e.g. AAPL) which already provision a portion of their overseas profits forUS taxes and have effective US tax rates well above 35%.Note that for companies for which our analysts provided estimates, we asked them toprovide cumulative overseas profits if possible, but in most cases this number reflectsoverseas cash. Thus, taxes paid could be slightly higher than we estimate given thatboth the Blueprint and Trump’s plans suggest a mandatory tax on all accumulatedoverseas profits, some of which may be permanently reinvested; here, the Blueprintsuggests a lower 3.5% tax for retained earnings not held in cash/equivalents, suggestingthat any additional taxes payable that we are not capturing are likely to be small.To calculate the % EPS impact from buybacks, we subtract the amount of taxes payablefrom total cash brought back for the S&P 500 ex. Financials & Real Estate (and for eachsector) and divide this by the market cap for the S&P 500 (and for each sector.) Wemultiply this % impact for the overall index by our 2018E EPS of $137 to determine thepotential EPS impact, applying various buyback scenarios (10-100%). We use 50% as abase case scenario, which is lower than the 80% brought back during the 2004 taxholiday, to be conservative.Border adjustments impact on EPSWe estimate the costs of goods imported and exported for each company using thelatest company filings, conversations with analysts, industry research, managementcommentary and the Input-Output accounts data published by the U.S. Department ofCommerce. For more information about the Input-Output accounts data, please refer tothe Bureau of Economic Analysis website at http://www.bea.gov/industry/io_annual.htm.When using the estimates based on Input-Output accounts, we adjust them to accountfor the varying foreign exposures of different S&P 500 industries. For companies thatsource products through importers (e.g. retailers), we only included the costs of goodsestimated to be directly imported by each company, as taxes pertaining to thoseimported goods should be paid by the importers themselves.We estimate the earnings impact of border adjustments based on the additional taxesthat companies would pay on the costs of imported goods sold in the US (nondeductible)and any reduction in taxes related to the production costs for exportedgoods (deductible). To calculate this, we multiple the net value of imported COGS by theassumed tax rate. Note that the net impact can be either positive or negative dependingon whether the company is a net importer or exporter. We assume a 50% haircut to theimpact to account for from alternate sourcing, currency rates and pricing power.Lower corporate tax rate impact on EPSWe estimate the normalized effective domestic tax rate of a company based onconversations with the analysts or the median 5-year domestic income tax rate. If acompany had a negative tax rate for a particular year, we exclude the tax rate of that24 Equity Strategy Focus Point | 29 January 2017year from the median calculation. For companies with normalized tax rates of more than75%, we assume 35%.The impact of a lower corporate tax rate on company earnings is directly proportional tothe difference between the current domestic tax rate and the proposed tax rate. Theimpact is calculated by taking the difference between the current tax rate and theproposed tax rate, and dividing it by (1-current tax rate).To calculate the impact of a lower corporate tax rate on the S&P 500 earnings, we candivide the change in the effective tax rate by (1 – the current effective tax rate).Interest deductibility impactWe estimate the cost associated with the removal of the net interest expense deductionfrom taxable income by multiplying the net interest expense by the tax rate.Equity Strategy Focus Point | 29 January 2017 25DisclosuresImportant DisclosuresBofA Merrill Lynch Research Personnel (including the analyst(s) responsible for this report) receive compensation based upon, among other factors, the overall profitability of Bank of AmericaCorporation, including profits derived from investment banking. 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