Tax reform is an important opportunity to make the U.S. significantly more competitive for all types of business investment, including vital foreign direct investment (FDI). U.S. subsidiaries of global companies generate precisely the types of high-value jobs and economic activities that should be encouraged through fundamental tax reform.
OFII strongly supports a significant reduction in the U.S. corporate income tax rate, elimination of unnecessary complexity and administrative burden, and establishment of a more transparent tax code that will provide the certainty businesses need to grow in the United States. These efforts must be carried out in a non-discriminatory manner that encourages global investment in the U.S. economy.
In April, the U.S. Department of Treasury proposed regulations touted as an effort to curb so-called "inversions." Proposals made under Section 385, however, go far beyond that purpose and would impose sweeping changes to how debt and equity are classified -- upending decades of case law, instituting subjective standards, and creating an unpredictable environment for multinational companies operating in the United States.