# Getting From Here to There: The Transition Tax Issue

 Title: Getting From Here to There: The Transition Tax Issue Author: Fleming, J. Clifton Jr.; Peroni, Robert J.; Shay, Stephen E. Note: Order does not necessarily reflect citation order of authors. 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. Full Text & Related Files: 155tn0069-Fleming.pdf (158.9Kb; PDF) 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. Terms of Use: This article is made available under the terms and conditions applicable to Other Posted Material, as set forth at http://nrs.harvard.edu/urn-3:HUL.InstRepos:dash.current.terms-of-use#LAA Citable link to this page: http://nrs.harvard.edu/urn-3:HUL.InstRepos:31958204 Downloads of this work:

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