Territorial Tax Proposal Leaves Many Open Questions


David Noren predicted that, as part of tax reform, Congress will pass some sort of territorial dividend exemption system for dividends from foreign subsidiaries. “The United States is probably not going to adopt a pure territorial tax system under which all foreign earnings of a US multinational group’s foreign subsidiaries would be exempt from US taxation,” Mr. Noren added, saying the new regime would have both revenue-raising and revenue-losing elements.