Submission No. 5 to Senate Committee on Finance – Comments Common to Options Y & Z

Abstract

The Senate Committee on Finance international tax reform staff discussion draft issued November 19, 2013 sets out two possible approaches (Option Y and Option Z) for international tax reform. This letter makes comments that are common to both Option Y and Option Z. The subject matter of these comments include:

1. Repeal of Indirect Foreign Tax Credit for Certain U.S. Persons

2. Characterization of Certain Business Entities

3. Strengthening Measures Against Corporate Expatriations

4. Implementing Tax Residency Based on Place of Incorporation Or Management & Control Being in the United States

This is Submission 5 of 7 Comment Letters Provided to the Committee.

Keywords: international tax reform, territorial system, deferral system, Option Y, Option Z, foreign tax credit, FTC, Check-the-box Entities

JEL Classification: H21, H25, K34, E62