Taxing the $2.5 Trillion

4 Pages Posted: 24 Feb 2017

See all articles by Susan C. Morse

Susan C. Morse

University of Texas at Austin - School of Law

Date Written: January 9, 2017


This article discusses a transition tax on deemed repatriated foreign earnings. It argues for a simple, rough-justice design and no offset for foreign tax credits. A delayed effective date would permit corporations to repatriate at the current system and under current rates to take advantage of foreign tax credits.

Keywords: Transition Tax, Deemed Repatriation, Foreign Tax Credits

JEL Classification: K34

Suggested Citation

Morse, Susan C., Taxing the $2.5 Trillion (January 9, 2017). Tax Notes, Vol. 154, No. 2, Jan. 2017, U of Texas Law, Public Law Research Paper, Available at SSRN:

Susan C. Morse (Contact Author)

University of Texas at Austin - School of Law ( email )

727 East Dean Keeton Street
Austin, TX 78705
United States

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