Submission No. 7 to Senate Committee on Finance -- Chairman's Staff Request for Comments on Certain Technical and Policy Issues Raised in the Staff Discussion Draft -- 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 also issued on November 19, 2013, titled “Chairman’s Staff Request for Comments on Certain Technical and Policy Issues Raised in the Staff Discussion Draft”, certain issues were listed and comments were requested. This letter responds to certain of those issues. Comments are provided for the following issues:

Issues Applicable to Options Y and Z

1. Deduction for dividends received by domestic corporations from certain foreign corporations.

2. Application of dividends received deduction to certain sales and exchanges of stock.

3. Inclusion of United States related income in subpart F income.

4. Low-taxed income treated as subpart F income.

6. Reform of foreign tax credit limitation.

Issues Applicable to Common Provisions within Discussion Draft

1. Treatment of previously deferred foreign income.

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

Keywords: international tax reform, territorial system, deferral system, Option Y, Option Z, subpart F, controlled foreign corporation, CFC, dividend-received deduction

JEL Classification: H21, H25, K34, E62