Eviscerating the Foreign Tax Credit Limitations and Cutting the Repatriation Tax - What's ETI Repeal Got to Do with It?
J. Clifton Fleming, Jr. & Robert J. Peroni, Eviscerating the Foreign Tax Credit Limitations and Cutting the Repatriation Tax - What's ETI Repeal Got to Do with It?, 104 Tᴀx Nᴏᴛᴇs 1393 (2004).
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.
Reprinted in 35 Tax Notes Int'l 1081 (2004).
104 Tax Notes