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

12 Pages Posted: 7 Dec 2007 Last revised: 27 Jun 2014

See all articles by George K. Yin

George K. Yin

University of Virginia School of Law

Date Written: January 8, 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.

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

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

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: or

George K. Yin (Contact Author)

University of Virginia School of Law ( email )

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