It is generally in society's best interest for companies to reinvest their money in the economy and citizens rather than hoarding it, hence the tax. This is ge

It is generally in society's best interest for companies to reinvest their money in the economy and citizens rather than hoarding it, hence the tax. This is generally not true. Consider two uses for a human - he can build a piece of factory or build a home. Suppose the factory has an NPV of $99, while the consumption value of the home has an NPV of $100. The best thing to do with this human's labor is building the home. If we have the AET, the corporation may be taxed $5 on this $100 if they don't build the factory. Therefore the corporation pays $100 for the human to build the factory, creating an NPV of $99 for society. If we don't have the AET, the corporation hoards the cash (or distributes it to shareholders) and the human then builds a home instead of building the factory. The only argument I can see is that ROI for on-shore use of funds has to be higher than the repatriation tax rate to justify bringing the money back, but so what? That just means that we're in an economic situation where no one thinks they can get a 35% ROI You just answered your own question. If you have an X% ROI overseas, the company needs to gain an X+35% ROI in the US for the investment to be equally profitable. If we eliminated the tax on global earnings, then companies will invest the money in projects with an ROI larger than X% and smaller than X+35% that they would not otherwise have done. Do you believe all possible domestic projects have an ROI either smaller than X% or larger than X+35%? That's the only way eliminating this tax wouldn't spur investment.