Resurfacing The Infrastructure Bonds Measure — From As Early As 2012 — For Tax-Advantaged Repatriation Of Overseas Parked Corporate Cash…
February 12, 2017

On an otherwise quiet, luminous and clear early Sunday morning, we will remind all our readers that we long thought, and now think, this measure makes solid sense.

We have referred to this in the past as “the Colorado compromise” bill. That’s one of our backgrounders on it. It is believed that if enacted, it would create a path for some of the estimated $1.8 trillion of overseas earnings to return to our shores and further stimulate our economy while ensuring high quality American jobs will be created in the process.

Specifically, then:

. . . .SEC. 966. Foreign earnings exclusion for purchase of infrastructure bonds.

(a) Exclusion. — In the case of a corporation which is a United States shareholder and for which the election under this section is in effect for the taxable year, gross income does not include an amount equal to the qualified cash dividend amount.

mrk-aapl-euro-2017(b) Qualified cash dividend amount.—For purposes of this section, the term ‘qualified cash dividend amount’ means an amount of the cash dividends which are received during a taxable year by such shareholder from controlled foreign corporations equal to—

(1) the multiplier determined under section 2(d)(5) of the Partnership to Build America Act of 2015 for such shareholder, multiplied by

(2) the face amount of qualified infrastructure bonds acquired at its original issue (directly or through an underwriter) by such shareholder. . . .

Essentially a very good (but candidly — as so many are — imperfect) idea. Now, will 45 have the vision to support it? I am uncertain — but Merck is approaching $82 billion in parked overseas cash, now. [Apple’s euro-based horde is multiples larger than Merck’s — or Pfizer’s.] So the time is ripe, after 45’s meetings with big pharma — and Mr. Frazier — last week. Certainly repatriation was discussed.

नमस्ते

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