13 Pages Posted: 5 Apr 2017 Last revised: 16 May 2017
Date Written: March 27, 2017
If there is fundamental U.S. international income tax reform, regardless of the reform option chosen, the United States must decide how to handle the $2.4 trillion to $2.6 trillion of previously untaxed foreign income accumulated by U.S. multinational corporations. In this report, Fleming, Peroni, and Shay argue that the proper approach is to treat the income as a subpart F inclusion in the year before the effective date of fundamental reform and to tax it at regular rates with an option to make the payments in installments that bear market-rate interest. The authors explain why the case for a low or deferred tax on this income is inferior to the case for full immediate taxation.
Suggested Citation: Suggested Citation
Fleming, J. Clifton and Peroni, Robert J. and Shay, Stephen E., Getting from Here to There: The Transition Tax Issue (March 27, 2017). 154 Tax Notes, March 27, 2017, at 69; U of Texas Law, Public Law Research Paper No. 671. Available at SSRN: https://ssrn.com/abstract=2945693