[20171212]IF10699_税收改革的关键问题：国际税务问题.pdf

https:/crsreports.congress.gov Updated December 12, 2017Key Issues in Tax Reform: International Tax IssuesIssues surrounding the taxation of U.S. multinational corporations have been a major impetus for tax reform and are some of the main arguments for tax measures to lower the statutory corporate tax rate of 35% and revise the current system for taxing foreign source income. Current Law A territorial or source-based system taxes only income earned in the country and excludes foreign source income. A worldwide system taxes both income earned in the country and foreign source income, but allows a credit for income taxes paid to foreign jurisdictions. Most countries have largely territorial systems. The U.S. system has elements of both. While it taxes worldwide income, earnings of foreign subsidiaries of U.S. multinationals are not taxed until they are repatriated (paid as dividends to the parent). Earnings of foreign branches and royalties and interest payments are taxed currently. A foreign tax credit is allowed, but limited to the total U.S. tax due. This limit is applied separately to active and passive income. This overall limit allows cross-crediting so that firms can use exce