The growth in permanently reinvested earnings is particularly noteworthy because a large amount of PRE was eliminated through the large repatriations during the tax holiday provided by the American Jobs Creation Act of 2004. On the other hand, since PRE was one of the factors that determined the amount of foreign earnings that was subject to the favorable holiday rates in the 2004 Act, managers may be classifying as PRE as much foreign profits as possible so that their total PRE is as large as possible in the future. In other words, if managers believe that tax rates will be temporarily reduced in the future and PRE will be a factor in determining the amount of dividends that can enjoy the low rate, firms have an incentive to overstate PRE now.