id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
ftr-349	Kleinbard, Edward D.	Stateless Income	2022	75	.pdf	application/pdf	34423	1276	45	Some of this $9.2 billion repatriation tax cost might be attributable to foreign withholding taxes, but those taxes in turn ordinarily are fully creditable in the United States; as a result, the division of the repatriation tax cost between foreign withholding tax and U.S. residual income tax does not affect the calculation summarized in the following sentence in the text. Second, untaxed foreign income paid to the U.S. parent in the form of interest or royalty payments can be sheltered from U.S. tax through the use of unrelated foreign tax credits (which would not be the case in a territorial regime).29 The United States fundamentally deviates from a worldwide tax norm by offering U.S. firms the opportunity for “deferral,” under which the active business earnings of a U.S. company’s foreign subsidiary (but not a foreign branch) are not taxed in the United States until those earnings are in some fashion repatriated to the U.S. parent.30 This “deferral” aspect of U.S. law is technically the base case.	cache/ftr-349.pdf	txt/ftr-349.txt