The Senate Finance Committee hosts a hearing today on The Foundation of International Tax Reform: Worldwide, Territorial, and Something in Between. From the press release:
Currently, U.S. businesses can postpone paying taxes on active business income earned overseas through a feature of the tax code called deferral. However, income from interest, rent, royalties and dividends from unrelated corporations, known as passive income, is exempt from deferral under Subpart F of U.S. Tax Code. Subpart F became part of the U.S. Tax Code in 1962. In light of the changes to the U.S. and global economy since 1962, the Committee will review Subpart F and examine how it relates to a global economy. The Committee, which has jurisdiction over the income tax, will also look at methods to reform the way the United States taxes foreign income of US taxpayers.
Here are the witnesses scheduled to testify:
- Professor James R. Hines, Jr. (University of Michigan Law School)
- Stephen E. Shay (Partner, Ropes & Gray, Boston, MA)
- Professor Roseanne Altshuler (Rutgers University)
- Robert H. Dilworth (Partner, McDermott Will & Emery LLP, Washington, D.C.)
In connection with the hearing, the Joint Committee on Taxation has released Economic Efficiency And Structural Analyses Of Alternative U.S. Tax Policies For Foreign Direct Investment (JCX-55-08).
The hearing takes place this morning at 10:00 a.m. in 215 Dirksen Senate Office Building. For more, see here.



