US mulling foreign profits overhaul

US Senate panel hears testimony from tax experts as it considers the possibility of easing the burden on US citizens' overseas income

Written by David Jetuah

A sweeping reform of international tax rules could be on the cards in the US.

Senators have been hearing evidence from tax experts as they look at the possibility of easing the tax burden on the foreign income of US taxpayers and businesses.

'Put simply, the United States is close to unique among world nations in taxing foreign income in the way that we do, James R. Hines, a professor at the University of Michigan Law School in his testimony to the US Senate finance committee. 'Not only does the United States subject active foreign business income to domestic taxation, but we do so in a manner that strictly limits the ability of taxpayers to claim foreign tax credits and to avoid current U.S. taxation of unrepatriated foreign income,' WebCPA reported.

The chances of a change to the rules governing both individual and business taxes on income earned abroad were met with reluctance from some quarters.

'There is no a priori reason for allowing a special position for foreign business income, whether the income is earned directly by individuals or indirectly through foreign activities of U.S. or foreign corporations,' said Stephen E Shay of Boston law firm Ropes & Gray.

'If U.S. taxation of foreign business income is lower than on domestic business income, U.S. persons who do not earn foreign business income will be subject to heavier taxation solely because of where their business is located. To justify relief from U.S. tax on foreign business income, there should be an identifiable benefit to individual U.S. citizens and residents.'

Further reading:

Advisers call for extension of non-dom amendment

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