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IPS152 Ryan N.
                While most holding company MOUSAs (489 of 652, or 75 percent) host
            pass-through equity, SPEs in the United States, in general, are unlikely to do
            so. Of 4,653 SPEs identified, only 437 have pass-through equity. This absence
            of pass-through equity may indicate that SPEs in the United States are used
            for  purposes  other  than  pass-through  equity  and  that  because  the  United
            States is not a “country of convenience,” foreign MNEs are likely using other
            countries for pass-through activities.

            4.      Discussion and Conclusion
                This paper represents a first attempt to identify and analyze SPEs in U.S.
            direct investment statistics using the TFSPE’s definition. This paper shows that
            SPEs play a much larger role in U.S. direct investment abroad than in foreign
            direct investment in the United States. SPEs—particularly nonresident SPEs—
            host  a  large  amount  of  pass-through  capital  that  moves  from  the  parent
            company through an intermediary country before reaching the country where
            economic  production  occurs.  The  large  overlap  between  SPEs  and  pass-
            through equity in the U.S. direct investment data is an indication that the SPE
            criteria developed by TFSPE will be useful in isolating SPEs in international
            investment statistics and that by identifying SPEs—particularly in “countries of
            convenience”—most pass-through activity will be identified as well. Additional
            work to fit the TFSPE’s definition of SPEs to BEA microdata will allow BEA to
            further refine this identification. In particular, understanding which real estate
            affiliates in the United States are truly SPEs will provide clarity about the role
            of U.S.-resident SPEs in inward direct investment.
                In addition to gaining a clearer understanding of the role of SPEs in such
            pass-through relationships, this paper outlines progress toward a framework
            for “pushing down” the U.S. direct investment position past SPEs to operating
            units and providing a clearer picture of how U.S. direct investment abroad
            relates to economic production in foreign countries. Future research will be
            able to study the distribution of U.S. direct investment after the elimination of
            pass-through.





















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