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It has been a regular refrain from corporate America's chief executives, "Corporate tax in this country needs to be reformed," Jeffrey R. Immelt, the chief executive of General Electric, has said repeatedly. Timothy D. Cook, Apple's chief executive, told lawmakers, "Apple has recommended to the Obama administration and several members of Congress — and suggests to the subcommittee today — to pass legislation that dramatically simplifies the U.S. corporate tax system."
On Monday, the business world got its wish from President Obama — a proposed overhaul of corporate tax policy in the United States — but not in the way it might have hoped.
President Obama's budget calls for a lower overall tax rate — 28 percent, down from 35 percent. But it also calls for a one-time 14 percent tax on all cash sitting overseas and a 19 percent tax on all foreign profits in the future, minus taxes paid abroad. The one-time tax would hit hardest the businesses with huge cash piles abroad like G.E. ($110 billion), Microsoft ($74 billion), Pfizer ($69 billion) and Apple ($54.4 billion).
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The plan was greeted by big business, at least privately, with disgust, if not disdain. It was called everything from "confiscatory" to "dead on arrival." Representative Paul D. Ryan, Republican of Wisconsin, chairman of the House Ways and Means Committee, said the president's budget was based on "envy economics."
Here's the rub: While chief executives often give lip service to the need for corporate tax reform — and some believe in it — when it comes right down to it, companies aren't necessarily interested in a simpler tax system, just one that significantly lightens their tax burden.
That's a pretty high hurdle when you consider that the true tax rate for cash sitting abroad isn't the statutory 35 percent, it's zero because foreign profits aren't taxed in the United States unless the money is brought back.
It helps explain why true tax reform is going to be so challenging: any rate higher than zero hits a company's bottom line.
Just last week, the senators Rand Paul, Republican of Kentucky, and Barbara Boxer, Democrat of California, proposed a one-time tax holiday that would allow companies to repatriate cash at a 6.5 percent rate and use the money to finance the Highway Trust Fund. That was considered too high by some executives because it was more than the 5.25 percent tax rate that Congress used when it granted a tax holiday in 2004. (Tax holidays, as I've mentioned in previous DealBook columns, are a terrible idea because they create a perverse incentive for companies to keep stashing cash abroad in hopes Congress will grant another tax holiday.)
And the idea of a mandatory one-time tax on all foreign cash is likely to run into opposition, even though such a tax is necessary for practical purposes as part of any transition to a more globally oriented tax regime.
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"A 14 percent tax on corporate earnings held overseas is totally out of the question; the White House threw out that figure as a first offer," Gregory R. Valliere, chief political strategist at the Potomac Research Group, wrote in a note to clients. "If that 14 percent figure was lowered to, say, 5 percent, then things might get very interesting."
It is worth noting that a 2014 proposal by Representative David Camp, Republican of Michigan and former chairman of the House Ways and Means Committee, who retired last year, included a one-time mandatory tax of 8.75 percent on foreign cash. Of course, that proposal didn't go anywhere, either.
"Obama's deemed repatriation tax isn't all that unreasonable of a plan," Jeremy Scott, editor in chief of Tax Analysts commentary, wrote. "The idea of using a reduced rate to tax profits permanently reinvested overseas has been a part of almost every serious international tax reform plan for the last several years."
If United States chief executives were focused on economic perspective, they would recognize that a one-time tax of 14 percent on overseas cash would cause little distortion or change in behavior as part of a transition to a new system that would tax all foreign income at 19 percent.
"Taxing those earnings as part of the transition to an entirely new international tax system will have no effect on future behavior, since the earnings hoard relates entirely to the past," Edward Kleinbard, a professor of law and business at the University of Southern California and former staff director of the Joint Tax Committee, told Congress last year. "Thus demands for a very low transition tax rate on the repatriation of existing foreign earnings in the context of tax reform are precisely backwards as an economic matter."
As for President Obama's plan to tax foreign profits regardless of whether they are brought home or not, the business community is, of course, already pushing back.
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"This is the wrong direction for corporate reform," James Pethokoukis of the American Enterprise Institute wrote. "Under a better territorial system, the I.R.S. would only seek to tax those profits earned in the United States. American companies with foreign-earned profits would be free to leave that dough overseas or bring them home without any further tax consequences. "
At issue is how our biggest companies pay taxes on foreign profits. In most other developed countries, companies pay taxes only to the jurisdiction in which they do business.
"The fact is I'd take Germany's or Japan's or the U.K.'s corporate tax policy today, sight unseen, without any dispute," Mr. Immelt said at Dartmouth College in 2011. "I would take any of those tax policies today."
The trillion-dollar question is whether any of these machinations around tax reform will spur the economy and job growth. And that remains open to debate.
"A repatriation deal could have a significant impact on stock buybacks, dividends, M.&A. activity, business fixed investment, etc.," Mr. Valliere said. "Whether it would lead to a surge in hiring is debatable; it didn't when earnings were repatriated a decade ago." (Companies that received the tax benefits on $150 billion of repatriated cash later cut at least 20,000 jobs.)
He puts the odds of Mr. Obama's proposal leading to a deal before the next election at 35 percent.
"Why not better odds?" he asked. "Because the vehicle would have to be corporate tax reform, and the details are daunting."