> My first problem is this: why exactly can't we treat companies the same way? Under current tax law, US corporations pay taxes on any income generated in anot

> My first problem is this: why exactly can't we treat companies the same way? Under current tax law, US corporations pay taxes on any income generated in another country. There is of course a loophole with regards to re-investing profits, but in general, companies have a tax liability on any profit they make anywhere in the world. In the article it talks about 3 different classifications of foreign income. Interest/Passive Income (has to have tax paid on it), non-reinvested income and re-invested (or promised to be) income. The 3rd category is the biggest loop hole, but the first 2 make a company pay taxes on that income to the US Treasury (after foreign tax credits). The third category basically is where all the deferred money sits - as long as the company promises it will be using that profit to invest in foreign parts of the company.