Getting From Here to There: The Transition Tax Issue

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Getting From Here to There: The Transition Tax Issue

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Title: Getting From Here to There: The Transition Tax Issue
Author: Fleming, J. Clifton Jr.; Peroni, Robert J.; Shay, Stephen E.

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Citation: J. Clifton Fleming, Jr., Robert J. Peroni & Stephen E. Shay, Getting from Here to There: The Transition Tax Issue, 154 Tax Notes, Mar. 27, 2017, at 69.
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Abstract: 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.
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