Abstract
Shay reviews what is known about and unrepatriated offshore earnings. He concludes that the limited evidence available does not support claims that economic harm from lockout justifies shifting to a territorial tax system.
Highlights
Shay reviews what is known about ‘‘lockout’’ and unrepatriated offshore earnings. He concludes that the limited evidence available does not support claims that economic harm from lockout justifies shifting to a territorial tax system
A 2011 Senate Permanent Subcommittee on Investigations (PSI) report stated that its survey of 27 U.S corporations with $538 billion of undistributed earnings in 2010 found that 46 percent of this amount was held in U.S financial institutions.[31]
If approximately half of total untaxed earnings are held in cash or equivalents, the PSI report and Standard & Poor (S&P)’s findings suggest that a very high percentage of these cash holdings are held in U.S financial investments
Summary
Shay is a professor of practice at Harvard Law School. He thanks Rosanne Altshuler, Cliff Fleming, David Saltzman, and others, who have asked to remain unidentified, for helpful comments on earlier drafts of this article. Shay reviews what is known about ‘‘lockout’’ and unrepatriated offshore earnings. He concludes that the limited evidence available does not support claims that economic harm from lockout justifies shifting to a territorial tax system. Uses of offshore earnings examined, the evidence does not support a claim that lockout is a primary reason to exempt multinationals’ foreign dividends from active business income.[4]
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