Legislative update: JCT report on taxation of repatriated foreign earnings

Legislative update: JCT report on repatriated earnings

The Ways and Means Committee’s Subcommittee on Select Revenue Measures has scheduled a public hearing for June 24, 2015, to examine the taxation of repatriated foreign earnings as a source of funding for the highway trust fund.


In advance of the hearing, the Joint Committee on Taxation today released a report (JCX-96-15) that describes the current tax treatment of the repatriation of foreign earnings as well as the financial accounting treatment of undistributed earnings of foreign subsidiaries under U.S. generally accepted accounting principles (GAAP).

The JCT report also:

  • Reviews recent tax reform proposals that have included a deemed repatriation
  • Discusses the economic impact and design of a one-time tax on historic foreign earnings
  • Highlights some issues concerning whether the one-time tax is mandatory or voluntary and whether it is enacted as part of broader reform of the international tax system

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