Eviscerating the Foreign Tax Credit Limitations and Cutting the Repatriation Tax - What's ETI Repeal Got to Do with It‘

28 Pages Posted: 18 Sep 2004 Last revised: 9 Jun 2015

See all articles by J. Clifton Fleming

J. Clifton Fleming

Brigham Young University - J. Reuben Clark Law School

Robert J. Peroni

University of Texas at Austin - School of Law

Abstract

This report analyzes the two bills, about to be taken up by House and Senate conferees, that would repeal the ETI regime. While agreeing that ETI repeal is proper, the authors think that several provisions are not connected to the ETI problem and are poor tax policy. They list two provisions - the House bill's reduction of the number of foreign tax credit limitation baskets and both bills' temporary repatriation tax cut - as the most egregious and argue that they will undermine the fairness and economic efficiency of the tax system, will do little to simplify international tax rules, and will provide unneeded subsidies to multinationals.

Suggested Citation

Fleming, J. Clifton and Peroni, Robert Joseph, Eviscerating the Foreign Tax Credit Limitations and Cutting the Repatriation Tax - What's ETI Repeal Got to Do with It‘. Tax Notes, Vol. 104, No. 13, September 20, 2004. Available at SSRN: https://ssrn.com/abstract=592861

J. Clifton Fleming (Contact Author)

Brigham Young University - J. Reuben Clark Law School ( email )

430 JRCB
Brigham Young University
Provo, UT 84602
United States

Robert Joseph Peroni

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

727 East Dean Keeton Street
Austin, TX 78705
United States

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