Tax Code in Transition: How to Treat Accumulated Untaxed Foreign Earnings

Lawmakers are on the verge of fundamentally updating the international provisions of the US tax code. Currently, we have a worldwide system, under which profits US firms earn abroad are subject to US tax minus a credit for foreign taxes paid and subject to a deferral until repatriation. In an effort that began in 2011 with draft legislation from former Ways and Means Chairman Dave Camp, Republicans have been determined to transform the US tax code into a territorial system, under which active income earned abroad is generally exempt from US tax.