Reform of the U.S. international tax policy is under consideration in Congress. Policymakers are concerned with both reducing tax disincentives to repatriate earnings to the U.S. and with constraining business tactics to move U.S. income offshore. We argue that to achieve significant tax reform,...

Under the current U.S. tax system, corporations have an incentive to defer the repatriation of their foreign earnings. This incentive is commonly referred to as the lock-out effect. The lock-out effect is significant, as estimates indicate that U.S. corporations hold nearly $2 trillion of...