Market leading insight for tax experts
View online issue

US Repatriation of Foreign Earnings

Gregg D Lemein Stewart R Lipeles John D McDonald Jefferson VanderWolk Partners Baker & McKenzie write on the new US legislation on tax-advantaged repatriation of foreign earnings
On 22 October 2004 President Bush signed the American Jobs Creation Act of 2004 which despite its name is entirely tax legislation. The Act repealed the tax subsidy for exports of manufactured goods that had been held to violate WTO rules and replaced it with a phased-in tax rate reduction for income from 'qualified production activities' undertaken in the US. The Act also beefed up the rules against tax shelters restricted the scope of tax-effective deferred compensation arrangements and made various changes to the foreign tax credit and controlled foreign company rules (subpart F).
If you are not a subscriber, subscribe now to read this content.
If you are already a subscriber, sign in
Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this article in full.