[Congressional Record Volume 161, Number 20 (Thursday, February 5, 2015)]
[Senate]
[Page S836]
From the Congressional Record Online through the Government Publishing Office [www.gpo.gov]

      By Mr. McCAIN:
  S. 397. A bill to amend the Internal Revenue Code of 1986 to allow a 
temporary dividends received deduction for dividends received from a 
controlled foreign corporation; to the Committee on Finance.
  Mr. McCAIN. Mr. President, today I introduce the Foreign Earnings 
Reinvestment Act that would generate the flow of an estimated $1.9 
trillion back into the American economy by temporarily allowing 
companies to return profits earned overseas to the U.S. at a reduced 
tax rate. It is no secret that one of the primary reasons why this 
money is laying idle and doing nothing to spur job creation is due to 
the fact that our Nation has the highest corporate tax rate in the free 
world at 35 percent. According to the Organisation for Economic Co-
operation and Development, OECD, when you add in additional State and 
local taxes the combined corporate rate jumps to a staggering 39.1 
percent. Whereas, the average combined corporate tax rate for the rest 
of the developed world, excluding the U.S. is around 25 percent.
  Congress has long debated tax reform and has failed to act. It is my 
hope that, under a Republican controlled Congress, we will be able to 
move forward with tax reform, which includes lowering both the personal 
and corporate tax rate and eliminating tax loopholes. If we are not 
going to act on behalf of the American taxpayer than we need to make 
available temporary tax incentives to bring this money back home 
providing a much needed boost to our economy.
  The Foreign Earnings Reinvestment Act would encourage American 
companies to bring overseas earnings back to the United States and 
creates strong incentives for those firms to invest these earnings in 
U.S. employees.
  Specifically, the bill would temporarily reduce the current 35 
percent corporate rate to an 8.75 percent effective rate on foreign 
earnings brought back to the United States. If companies are able to 
show that they are expanding their payroll by 10 percent through net 
job creation or higher payroll, the bill would allow these corporations 
to obtain up to a 5.25 percent effective repatriation rate In addition, 
the bill discourages U.S. companies from reducing employment by 
including in a company's gross income calculation of $75,000 per full-
time position that is eliminated.
  This common sense legislation will drive the roughly $1.9 trillion 
currently parked overseas back here to the United States, boosting our 
economy and spurring job creation.
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