The international part of the "Framework"

The bit on international in the "framework" is worth quoting in full:

"TERRITORIAL TAXATION OF GLOBAL AMERICAN COMPANIES

"The framework transforms our existing 'offshoring' model to an American model. It ends the perverse incentive to keep foreign profits offshore by exempting them when they are repatriated to the United States. It will replace the existing, outdated worldwide tax system with a 100% exemption for dividends from foreign subsidiaries (in which the U.S. parent owns at least a 10% stake).

To transition to this new system, the framework treats foreign earnings that have accumulated overseas under the old system as repatriated. Accumulated foreign earnings held in illiquid assets will be subject to a lower tax rate than foreign earnings held in cash or cash equivalents. Payment of the tax liability will be spread out over several years.

"STOPPING CORPORATIONS FROM SHIPPING JOBS AND CAPITAL OVERSEAS

"To prevent companies from shifting profits to tax havens, the framework includes rules to protect the U.S. tax base by taxing at a reduced rate and on a global basis the foreign profits of U.S. multinational corporations. The committees will incorporate rules to level the playing field between U.S.-headquartered parent companies and foreign-headquartered parent companies."

Let me see if I can make any sense of this. They say it's a territorial system. But they also say that they will be "taxing at a reduced rate and on a global basis the foreign profits of U.S. multinational corporations." This can formally be reconciled, in the sense that what they literally say up top is that they will offer dividend exemption.  Of course, a full worldwide system in which deferral (for the foreign profits of foreign subsidiaries) was repealed would also have dividend exemption. Bringing the foreign profits home would have no tax consequences, since those profits would already have been taxed.


Is that what they are saying, albeit with a reduced rate for foreign source income? Seemingly yes, but then how is it a "territorial" system? And if they are taxing U.S. companies' foreign source income, how do they propose to "level the playing field between U.S.-headquartered parent companies and foreign-headquartered parent companies"?

The repatriation tax is of course a welcome feature of switching to territorial, but the rate imposed is all important here.  I'm guessing it will end up being very low.  The dual feature, as between cash equivalents and illiquid assets, has a rationale but is likely to be messy at best in practice.