Submission No. 6 to Senate Committee on Finance -- Summary of Staff Discussion Draft -- Unaddressed Issues and Request for Comments -- Responses

Abstract

The Senate Committee on Finance international tax reform staff discussion draft issued November 19, 2013 sets out certain proposals for international tax reform. In a document titled “Summary of Staff Discussion Draft” issued on November 19, 2013 of the proposals, certain “Unaddressed Issues” were listed and comments were requested. This letter responds to certain of those "Unaddressed Issues". Comments are provided for the following "Unaddressed Issues":

1. The pros and cons of the two options for taxing foreign market activities of foreign subsidiaries of U.S. businesses.

2. The relative merits of Chairman Camp’s Option C as compared with the proposals in this Senate Finance Committee staff discussion draft.

3. The treatment of foreign branches.

4. Consideration of a "unitary" approach to international taxation.

9. International tax rules affecting individuals.

This is Submission 6 of 7 Comment Letters Provided to the Committee.

Keywords: international tax reform, territorial system, deferral system, Option Y, Option Z, Option C, Camp Discussion Draft, expatriate taxation

JEL Classification: H21, H25, K34, E62