The Rise and Fall of Hope and Change

The Rise and Fall of Hope and Change



Alexis de Toqueville

The American Republic will endure until the day Congress discovers that it can bribe the public with the public's money.
Alexis de Tocqueville

The United States Capitol Building

The United States Capitol Building

The Constitutional Convention

The Constitutional Convention

The Continental Congress

The Continental Congress

George Washington at Valley Forge

George Washington at Valley Forge


Sunday, December 25, 2011

Rethinking U.S. Taxation of Overseas Operations: Subpart F, Territoriality, and the Exception for Active Royalties

From The Heritage Foundation:

Budget & Taxation






Rethinking U.S. Taxation of Overseas Operations: Subpart F, Territoriality, and the Exception for Active Royalties



by Joseph Henchman



Tax Foundation



November 28, 2011







U.S. corporations operating overseas face a combination of burdens not borne by their international competitors: taxes owed to the United States, taxes owed to the country where the operating activity takes place, and a complex tax system that attempts to reduce the resultant economic harm but involves an array of credits and definitions (Subpart F). To enhance international trade competitiveness a territorial taxation system would be more favorable and would reduce compliance costs, prevent capital “lockout” effects, and remove impediments that discourage foreign firms from headquartering in the United States. Subpart F should be scrubbed of policies that no longer work in today’s global economy. The “related parties” exception may have been meant to discourage firms from operating as overseas tax havens, but instead introduces uncertainty and distortions for legitimate business activity.





URL: taxfoundation.org/files/sr197.pdf

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