CIS/Index
Copyright © 1999, Congressional Information
Service, Inc.
1 CIS H 78145
TITLE: Impact of U.S.
Tax Rules on International Competitiveness
CIS-NO: 2001-H781-45
SOURCE: Committee on Ways and Means. House
DOC-TYPE: Hearing Retrieve
the full text of testimony
DATE: June 30, 1999
LENGTH:
iv+217 p.
CONG-SESS: 106-1
ITEM-NO: 1028-A; 1028-B
SUDOC: Y4.W36:106-92
MC-ENTRY-NO: 2001-11234
GPO-STOCK-NO: 552-070-26712-3.
SUMMARY:
Committee Serial No. 106-92. Hearing to review U.S. income tax treatment of
U.S. individuals and corporations with foreign income, including income from
operations of U.S. controlled foreign corporations (CFCs) under Internal Revenue
Code subpart F, and to examine the need to revise and simplify the U.S.
international tax system to reduce U.S. competitive disadvantage (Subcom
advisory, p. 2-4).
Briefly considers H.R. 2018, the International
Tax Simplification for American Competitiveness Act of 1999, to revise the U.S.
international tax system.
Supplementary material (p. 152-217)
includes submitted statements and correspondence.
CONTENT-NOTATION: Income tax treatment of US business
and individual foreign-source income
BILLS: 106
H.R. 2018
DESCRIPTORS:
TAX INCENTIVES AND SHELTERS; INCOME TAXES; MULTINATIONAL
CORPORATIONS; BUSINESS INCOME; FOREIGN ECONOMIC RELATIONS; COMPETITION;
INTERNATIONAL TAX SIMPLIFICATION FOR AMERICAN COMPETITIVENESS ACT; CORPORATIONS;
FOREIGN CORPORATIONS
01-H781-45 TESTIMONY NO: 1 June
30, 1999 p. 5-11
WITNESSES (and witness notations):
LEVIN, SANDER M. (Rep, D-Mich)
HOUGHTON, AMO (Rep, R-NY)
STATEMENTS:
Merits of H.R. 2018.
CONTENT NOTATION:
Income tax treatment of US business and individual
foreign-source income, revision
01-H781-45 TESTIMONY
NO: 2 June 30, 1999 p. 12-47
WITNESSES (and
witness notations):
GREEN, RICHARD C., JR. (CEO, UtiliCorp
United)
LOFFREDO, JOHN L. (Vice President and Chief Tax
Counsel, DaimlerChrysler Corp)
LIPNER, ALAN J. (Senior
Vice President, Taxes, American Express Co)
STILES, SALLY
A. (International Tax Manager, Caterpillar Inc)
FINNERTY,
PETER J. (Vice President, Public Affairs, Sea-Land Service; also representing
CSX Corp)
STATEMENTS AND DISCUSSION:
Concerns about impact of U.S. tax rules on U.S. business
international competitiveness; recommendations to revise U.S. international tax
system; adverse impact of U.S. international tax system on competitiveness of
U.S.-flag commercial fleet.
CONTENT NOTATION:
Income tax treatment of US business and individual
foreign-source income
TESTIMONY DESCRIPTORS:
UTILICORP UNITED; MERCHANT MARINE; FOREIGN TRADE
01-H781-45 TESTIMONY NO: 3 June 30,
1999 p. 47-100
WITNESSES (and witness notations):
HUBBARD, GLENN R. (Professor, Economics and Finance,
Graduate School of Business, Columbia University; representing International Tax
Policy Forum)
MURRAY, FRED F. (Vice President, Tax Policy,
National Foreign Trade Council (NFTC))
MORRISON, PHILLIP
D. (Principal nd Director, D.C. International Tax Services Group, Deloitte &
Touche LLP)
MERRILL, PETER R. (Principal, D.C. National
Tax Services Office, PricewaterhouseCoopers LLP; both representing NFTC)
BOUMA, HERMANN B. (international tax attorney)
STATEMENTS:
Impact of U.S. tax rules on competitive
ability of U.S. multinational corporations; findings and recommendations of NFTC
foreign income project, taken in response to concerns about disparity between
U.S. trade policy and U.S. tax policy; concerns about tax treatment of income
from CFC operations.
Background on U.S. international tax
system, with recommended improvements; unfavorable comparison of U.S. subpart F
and foreign tax credit regimes with comparable regimes of selected foreign
countries.
Review of tax considerations involved in
structuring of cross-border mergers and acquisitions; elaboration on
international tax system impact on U.S. company competitiveness.
CONTENT NOTATION:
Income tax treatment of US business
and individual foreign-source income
TESTIMONY DESCRIPTORS:
INTERNATIONAL TAX POLICY FORUM; FOREIGN LAWS; ECONOMIC
CONCENTRATION
01-H781-45 TESTIMONY NO: 4
June 30, 1999 p. 100-152
WITNESSES (and
witness notations):
CONWAY, KEVIN (Vice President, Taxes,
United Technologies Corp.; representing National Association of Manufacturers)
MOGENSON, HARVEY B. (Managing Director, Morgan Stanley
Dean Witter & Co.; representing Coalition of Service Industries)
CHIP, WILLIAM W. (Principal, Deloitte & Touche LLP;
representing European-American Business Council)
LAITINEN,
WILLIAM H. (Assistant General Tax Counsel, General Motors Corp)
HAMOD, DAVID (Executive Director, Section 911 Coalition)
DEAN, WARREN L., JR. (Chair, Transportation Group,
Thompson Coburn LLP; representing Subpart F Shipping Coalition)
STATEMENTS AND DISCUSSION:
Importance of international
tax system revision to various U.S. business sectors, with concerns of U.S.
manufacturing and service industry sectors; explanation of U.S. tax system
adverse impact on U.S. business ability to compete internationally.
Criticism of U.S. tax rules regarding allocation
of interest expenses between U.S. and foreign source income for
purposes of determining tax credit a U.S. multinational company may claim for
taxes paid in foreign countries; importance of and need to increase section 911
foreign earned income exclusion available to U.S. taxpayers working abroad.
CONTENT NOTATION:
Income tax treatment of
US business and individual foreign-source income
TESTIMONY
DESCRIPTORS:
NATIONAL ASSOCIATION OF MANUFACTURERS
LOAD-DATE: January 31, 2002 
