1. Optimal Foreign Investment and International Trade
2. President Carter announced an intention to end deferral entirely in 1978. See Message from the President of the United States, Transmitting Proposals for Tax Reductions and Reform;S;Fact Sheet on John Kerry's Plan to Create 10 Million Jobs,1971
3. Territorial" Tax Reform, supra note 14. 154. The Obama Administration's 2011 budget proposed to expand the scope of Subpart F to currently tax "excessive" returns from transfers of intangible property to "low-tax" jurisdictions. See STAFF OF JOINT COMM. ON TAXATION, 111TH CONG., DESCRIPTION OF REVENUE PROVISIONS CONTAINED IN THE 1. Failure to Address Inbound Erosion Residency-based solutions (like subpart F reforms) that leave in place the preference for One-Sided Transfer Pricing Methodologies and then attempt to ring-fence the resulting transfer pricing mistakes are underinclusive because such residency-based reform proposals only address U.S. MNEs in an ad hoc manner and entirely ignore the HI/BEPS strategies of non-U.S. MNEs. In reality, the HI/BEPS problem is equally present with both U.S. and non-U.S. MNEs. 158 Consequently, residency-based reforms that target U.S. MNEs and leave non-U.S. MNEs free to base-erode the United States creates incentives for U.S. MNEs to search for base erosion strategies;Kerry;'s election platform tax plan sought to immediately tax all corporate income, whether earned domestically or internationally. Id. 153. See Michael Durst,2011
4. Treasury officials advise that the excessive return proposal does not conflict with U.S. transfer pricing or treaty obligations, since it is a Subpart F proposal;President's Fiscal Year;BUDGET PROPOSAL,2010