Stimulating the Stimulus: U.S. Controlled Subsidiaries and I.R.C. 965

Abstract

Recently, there has been much debate about how and when to balance the federal budget. Economists have examined how to safely raise taxes without stifling crucial growth in a fragile economic climate. This Note argues that a method already exists for tapping additional, secure sources of funding, namely the taxation of repatriated earnings from foreign subsidiaries. The Note explores the advantages and disadvantages of reenacting a tax break on foreign profits returning to the U.S. and concludes that the reenactment of this tax break coupled with major revision of the tax code will improve the taxation of U.S. businesses with subsidiaries abroad. These two acts are keys to a more honest and more effectual international tax system.