Having completed the first 4 (out of 7) chapters of my book-in-progress, "Fixing the U.S. International Tax Rules," I've now decided on a detour that may take me a couple of months. To give one of its relatively novel ideas more prominence, I'm going to write a stand-alone article entitled "The Case Against Foreign Tax Credits."
I've written a one-paragraph abstract, but feel like keeping it up my sleeve (or under my hat?) for now. But readers who know that I favor moving towards exemption for what we classify as "outbound" investment will correctly surmise that I am not in fact proposing a hefty (or any) tax increase for it via the elimination of foreign tax creditability.
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