Submission to House Ways & Means Committee in Connection with June 13, 2013 Hearing on Tax Reform: Tax Havens, Base Erosion and Profit-Shifting

Abstract

This submission to the House Ways & Means Committee following its June 13, 2013 "Hearing on Tax Reform: Tax Havens, Base Erosion and Profit-Shifting" adds some practical points to supplement what Professor Kleinbard presented at the hearing regarding his recommended worldwide tax consolidation approach to international tax reform as compared to the alternatively proposed territorial system. It also provides comments on Option C, which Professor Kleinbard said was absolutely impossible to administer, concerns that Mr. Oosterhuis, another speaker, merely dismissed. Finally, it suggests an approach regarding taxation of the accumulated overseas earnings that is now reportedly approaching $2 trillion.

Keywords: International Tax Reform, Full-Inclusion System, Worldwide Tax Consolidation, Territorial System

JEL Classification: H21, H25, K34, E62