What’s New with Cross-Border Income?

What’s New with Cross-Border Income?

On March 16, 2015, the Joint Committee on Taxation of the U.S. Congress (“JCT”) released a report on a number of topics related to the U.S. taxation of cross-border income. The report is entitled, “Present Law and Selected Policy Issues in the U.S. Taxation of Cross-Border Income.”
The Senate Committee on Finance had a public hearing on March 17, 2015, titled, “Building a Competitive U.S. International Tax System.” The document prepared by JCT staff covers a number of topics related to the U.S. taxation of cross-border income, including the following:

• a description of general international principles of taxation and how they are applied in the US tax system;
• an overview of US present law related to the taxation of cross-border income;
• a discussion of selected issues that have been of particular interest to policymakers as they evaluate the US international tax system, including:
  • the competitiveness of the US tax system;
  • the economic distortions arising from deferral;
  • the shifting of income and business operations away from the United States;
  • the tax incentive to locate deductions in the United States; and
  • inversions; and
• background data on cross-border income flows and economic activity, including mergers and acquisitions.

The full report and hearing recording are available for download at the following sites:

Present Law and Selected Policy Issues in the U.S. Taxation of Cross-Border Income Report

Building a Competitive U.S. International Tax System Public Hearing Recording