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

George K. Yin

University of Virginia School of Law

January 8, 2008

118 Tax Notes 173 (2008)

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: 12

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

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

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Date posted: December 7, 2007 ; Last revised: June 27, 2014

Suggested Citation

Yin, George K., Reforming the Taxation of Foreign Direct Investment By U.S. Taxpayers (January 8, 2008). 118 Tax Notes 173 (2008). Available at SSRN: http://ssrn.com/abstract=1054841 or http://dx.doi.org/10.2139/ssrn.1054841

Contact Information

George K. Yin (Contact Author)
University of Virginia School of Law ( email )
580 Massie Road
Charlottesville, VA 22903
United States
434-924-7025 (Phone)
434-924-7536 (Fax)

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