repatriating companies—which accounted for 52% of the total repatriated amount— actually reduced their US workforce and decreased their R&D spending following the repatriation act. The authors of the NBER study point out that cash is fungible, and firms 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 estimates for the proportion of repatriated cash by industry are in Table 8. Table 7: Top 15 repatriating companies based on the 2004 HIA Table 8: Corporations Repatriating Dividends Under IRC Section 965, Company Repatriated Amount ($bn) Selected Items, by Selected Major and Minor Industry of the Parent Pfizer 355 Corporation, Tax Years 2004-2006 Merck 15.9 Industry % of Repatriated Cash Dividends Hewlett Packard 145 Pharmaceutical and medicine manufacturing 29% Johnson & Johnson 107 Computer and electronic equipment manufacturing 19% Other manufacturing 8% BM ua Food manufacturing 6% sehering:Plaugh pe Other chemical manufacturing 5% Bristol Myers 9.0 Information {including software publishers} 4% Eli Lilly 8.0 Finance, insurance, real estate, rental and leasing 4% DuPont TT Transportation equipment manufacturing 3% Pepsi Co, Inc. 14 Management of companies and enterprises 3% Intel 6.2 All other industries 2% Coca-Cola 61 Paper manufacturing 2% Altria 60 Machinery manufacturing 2% Procter & Gamble 58 Electrical equipt, appliance & component manufacturing 2% Oracl 34 Other services 2% Tagle , Basic chemical manufacturing 2% Source: Data provided by corporations in response to U.S. Senate Permanent Subcommittee on Fabricated metal product manufacturing 1% Investigations survey 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 estimates Source: IRS