06-08-2010, 07:54 PM
1. Lower the rate to 20% to 25%.
2. Change the taxation of foreign corporations that sell into the US. Our entire system is set up to give them tax favored status, and our response is to penalize US based companies that have overseas operations. Completely ass backwards.
Two options
A. VAT, or
B. Expand the permanent establishment rules for any company selling into the US. For any company that is taxable in the US, we tax them under a unitary business concept on worldwide income and give a tax credit for foreign taxes paid up to the US tax rate.
Foreign countries would have a cow, but are those companies going to abandon the US marketplace? Not hardly.
US companies would lose the tax deferral of controlled foreign corporations, but the tradeoff would be a lower corporate tax rate, and they would be able to repatriate capital at will when needed.
2. Change the taxation of foreign corporations that sell into the US. Our entire system is set up to give them tax favored status, and our response is to penalize US based companies that have overseas operations. Completely ass backwards.
Two options
A. VAT, or
B. Expand the permanent establishment rules for any company selling into the US. For any company that is taxable in the US, we tax them under a unitary business concept on worldwide income and give a tax credit for foreign taxes paid up to the US tax rate.
Foreign countries would have a cow, but are those companies going to abandon the US marketplace? Not hardly.
US companies would lose the tax deferral of controlled foreign corporations, but the tradeoff would be a lower corporate tax rate, and they would be able to repatriate capital at will when needed.