Reforming the Taxation of Foreign Direct Investment By U.S. Taxpayers

Abstract:     
This paper discusses the 2005 proposal of President Bush's Advisory Panel on Federal Tax Reform to enact a dividend-exemption system for certain foreign-source earnings of U.S. taxpayers. The paper briefly explains why the recommendation should be an improvement over current law, compares it to a proposal to repeal deferral altogether and to certain international tax reform ideas recently put forward by House Ways and Means Committee Chairman Rangel, and describes three possible modifications to the Panel's recommendation. An abbreviated version of this paper was presented at the National Tax Association's 100th Annual Conference on Taxation, Columbus, Ohio, in November, 2007, as part of a panel to "cherry-pick" certain of the Tax Reform Panel's recommendations.

Number of Pages in PDF File: 29

Keywords: international tax reform, dividend-exemption, foreign direct investment, deferral

JEL Classification: F00, H00, H20, H25, K34

working papers series