Tuesday, March 27, 2012
Stephen E. Shay (Harvard) presents Unpacking Territorial (with J. Clifton Fleming (BYU) & Robert J. Peroni (Texas)) at NYU today as part of its Colloquium Series on Tax Policy and Public Finance convened by Daniel Shaviro (NYU) & Alan Aurbach (UC-Berkeley; visiting at NYU):
The paper ... evaluates the House Ways and Means Majority discussion draft proposal to shift the United States from its current system of deferring taxation of active foreign income to a territorial system that would exempt active foreign income from United States tax. The paper evaluates the proposal’s approach to important structural issues that arise in the design of and transition to a territorial system including the scope of exemption, the treatment of foreign branches; the allowance of domestic expenses to earn exempt foreign income, the scope of foreign source income and allowable tax credits, and treatment of pre-effective date earnings. The paper considers the expected effects of the proposal in relation to current law on U.S. multinational investment abroad, repatriation of foreign subsidiary earnings, administration and compliance burden and Federal revenues.