id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
ftr-323	Fleming, Jr., J. Clifton; Peroni, Robert J.; Shay, Stephan E.	Designing a U.S. Exemption System for Foreign Income When the Treasury is Empty	2022	64	.pdf	application/pdf	29378	1213	50	When the Treasury is Empty 399 most foreign-source active business income earned by U.S. resident corporations would become substantially free of U.S. income tax. Implicit Taxes Return now to the earlier example of USCo, a U.S. resident corporation paying U.S. income tax at a 35 percent rate, and its wholly owned, active business subsidiary, FS, which is incorporated in Lowtaxia, a country without a corporate profits tax or a dividend withholding tax.73 Assume that the United States and Lowtaxia are the world’s only countries, that U.S. corporations like USCo can earn a 10 percent pre-tax return on investments in U.S. business activities, and that the United States provides a tax exemption for all dividends from foreign subsidiaries regardless of whether the subsidiaries have paid any foreign tax.	cache/ftr-323.pdf	txt/ftr-323.txt