jurisdictions, such as Japan, are also realising the extent to which IP-based BEPS tools are being used to manage global corporate taxes. U.S. as BEPS winner While the IRS has traditionally been seen as the main loser to global corporate tax havens, the 15.5% repatriation rate of the Trump administration Tax Cuts and Jobs Act of 2017 changes this calculus. IP-heavy American corporations are the main users of BEPS tools. Studies show that as most other major economies run "territorial" tax systems, their corporates did not need to profit shift. They could just sell their IP to foreign markets from their home jurisdiction at low tax rates (e.g. 5% in Germany for German corporations). For example, there are no non-U.S./non-U.K. foreign corporates in Ireland's top 50 firms by revenues, and only one by employees, German retailer Lidl (whereas 14 of Ireland's top 20 firms are American multinationals). The British firms are mainly pre . (discussed here). Had American multinationals not used IP-based BEPS tools in corporate tax havens, and paid the circa 25% corporation tax (average OECD rate) abroad, the IRS would have only received an additional 10% in tax, to bring the total effective American worldwide tax rate to 35%. However, after the TCJA, the IRS is now getting more tax, at the higher 15.5% rate, and American corporations have avoided the 25% foreign taxes and therefore will have brought more capital back to America as result. This is at the expense of higher-tax Europe and Asian countries, who received no taxes from American corporations, as the corporations used IP-based BEPS tools from bases in corporate tax havens, while German corporations are charged 5% tax by their regulator. President Trump did not sign the OECD's June 2017 Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting, as it felt that it had low exposure to profit shifting. An American official said at a transfer pricing conference that they did not sign the tax treaty inked by 68 [later 70] countries in Paris 7 June 2017 "because the U.S. tax treaty network has a low degree of exposure to base erosion and profit shifting issues." This beneficial effect of global tax havens to the IRS was predicted by Hines and Rice in 1994 in which the authors said: "some American business operations are drawn offshore by the lure of low tax rates in tax