[20171204]IF10640_税收改革：外国收入汇回.pdf

https:/crsreports.congress.gov Updated December 4, 2017Tax Reform: Repatriation of Foreign EarningsA 2016 report released by the U.S. Public Interest Research Group, Citizens for Tax Justice, and the Institute on Taxation and Economic Policy estimated that Fortune 500 companies held nearly $2.5 trillion in accumulated profits offshore for tax purposes. Taxing these offshore profits has been discussed as a means to pay for several policy goalsincluding infrastructure investment and lowering corporate statutory rates. Brief Summary of Current Law The United States bases its jurisdiction to tax international income on residence. As a result, U.S.-chartered corporations are taxed on their worldwide income, but foreign corporations are taxed only on their U.S.-source income. Accordingly, a U.S. firm with overseas operations can indefinitely postpone paying its U.S. tax on its foreign income by operating through a foreign subsidiary. Using the same principle, U.S. taxes are deferred as long as the firms foreign earnings remain in the control of its foreign subsidiary and are reinvested abroad. The U.S. firm pays taxes on its overseas earnings only when they are paid to the U.S. parent c