Abstract
The Senate Committee on Finance international tax reform staff discussion draft issued November 19, 2013 sets out two possible approaches (Option Y and Option Z) for international tax reform. This letter makes comments that are common to both Option Y and Option Z. The subject matter of these comments include:1. Repeal of Indirect Foreign Tax Credit for Certain U.S. Persons2. Characterization of Certain Business Entities3. Strengthening Measures Against Corporate Expatriations4. Implementing Tax Residency Based on Place of Incorporation Or Management & Control Being in the United StatesThis is Submission 5 of 7 Comment Letters Provided to the Committee.
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