Abstract
The American Jobs Creation Act (AJCA) of 2004 eliminated the Extraterritorial Income provision (found to be an export subsidy), a change that improved economic efficiency and tax administration, as was likely the case with a number of tax shelter provisions. A provision allowing a special deduction from taxable income for manufacturing and certain other industries is likely to increase distortions and add complexity to the code. A temporary repatriation tax holiday for foreign source income is also likely to reduce revenue with little justification. Other foreign tax provisions are, however, more difficult to evaluate.
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