Craig Boise (Case Western; moving to DePaul) presents Breaking Open Offshore Piggybanks: Redux at Wake Forest today as part of its Faculty Development Program.  Here is the abstract:

In his 2007 article, Breaking Open Offshore Piggybanks: Deferral and the Utility of Amnesty, 14 Geo. Mason L. Rev. 667, Craig Boise compared the repatriation tax break provided by § 965 (part of the American Jobs Creation Act of 2004) to another familiar tax administration device, the tax amnesty. Section 965 shared with most tax amnesties the promise of generating significant revenue, a limited effective period, and the expectation that it would be a one-time occurrence. Based on the substantial literature on tax amnesties surveyed in the article, Boise suggested that § 965 would likely have a minimal effect in reducing the problem of deferral that it was in part intended to address, and that an expectation would be created that such a provision would be offered again in the future. Three years after the closing of § 965's repatriation window, its re-enactment is being called for by pharmaceutical and technology companies and has been made part of various pieces of legislation being considered by Congress. Boise again argues that a provision like § 965 not only does not adequately address the problem of deferral but is also unlikely to deliver the stimulus to the economy that its proponents promise.