In other words, companies would only be able to take a deduction on their U.S. taxes for foreign expenses when they also pay taxes on their foreign profits in the United States.
This makes sense. The proposal isn't forcing a company to pay extra taxes. It simply places tax incentives on layaway until the company pays its foreign taxes.
The question is: do foreign taxes count as expenses? They ought to.
Expences are deductibe form income, whereas typcial foreign tax credit is substracted from the domsectic tax itself. I bet it's the latest, as is the case for the personal income tax.
In other words, companies would only be able to take a deduction on their U.S. taxes for foreign expenses when they also pay taxes on their foreign profits in the United States.
This makes sense. The proposal isn't forcing a company to pay extra taxes. It simply places tax incentives on layaway until the company pays its foreign taxes.
The question is: do foreign taxes count as expenses? They ought to.
http://www.treas.gov/press/releases/tg119.htm