The ABA Tax Section convened a Task Force on International Tax Reform to provide policymakers with objective criteria by which to evaluate reform proposals and to identify and analyze possible modifications to the U.S. international tax rules.  The Task Force recently completed a 200-page Report, which will be published in 59 Tax. Law. 649 (2006).  The unedited final draft of the Report’s Table of Contents and first Chapter, which sets out the objectives and overview of the Report, is available here.   Here are excerpts from the Objectives of the Report:

This Report considers the taxation of U.S. persons’ foreign business income. The Report identifies and evaluates possible changes to current law, but does not make legislative recommendations.

While there is current questioning as to whether an income tax should be replaced with a consumption tax, the income tax is unlikely to be displaced. The problems of transition and the rates that would be required to achieve revenue neutrality, as well as other problems, are extremely daunting. The Report proceeds on the assumptions that the income tax will be retained as a material element of the U.S. tax system and that the United States will continue to impose an income tax on business income.