Foreign-Derived Deduction, AMT Repeal Top 91成人 Priorities for Tax Conference
Wednesday, Dec 06, 2017, 9:30pm
by 91成人
With both the House and Senate having passed sweeping tax reform bills recently, a conference committee is expected to convene soon to reconcile differences in the respective bills and set forth final legislation to be approved by Congress and sent to the President for signature. In a , 91成人 yesterday offered its priority recommendations for the final bill.

91成人鈥檚 longstanding goals for corporate tax reform are to achieve a globally competitive statutory rate, modernize America鈥檚 international tax system, and preserve incentives for U.S. research and development (R&D). We are very pleased that both the House and Senate bills meet these goals. However, how the conference committee reconciles key differences between the bills will significantly impact the ultimate benefits of the reforms.
First, the Senate bill鈥檚 late retention of the corporate Alternative Minimum Tax (AMT) effectively repeals the R&D credit, and potentially undermines several major international reforms. As a highly research-intensive industry with over 80 percent of sales abroad, 91成人 is gravely concerned about the impact of the AMT on domestic semiconductor research, and we have urged conferees to adopt the House position of full corporate AMT repeal.
Second, we generally favor the balanced international reforms contained in the Senate bill. 91成人 strongly supports the foreign-derived intangible income deduction 鈥 creating an effective 12.5 percent rate on income from intellectual property (IP) and technology held in the U.S. 鈥 and provisions for the distribution and favorable treatment of IP repatriated to the U.S. The combination of these two provisions will expand the U.S. tax base, improve the competitiveness of the American semiconductor industry, and help keep semiconductor IP and manufacturing in America. We strongly urge their inclusion in the conference report to create a globally competitive incentive that will help keep the U.S. semiconductor industry among America鈥檚 leading exporters.
For too long, America鈥檚 stagnant corporate tax system has impeded growth and innovation in the U.S. semiconductor industry and throughout our economy. 91成人 has been a committed, public supporter of corporate tax reform. Last week, we supported the corporate reforms in legislation reported out of the Senate Finance Committee, which included AMT repeal. In March, we supported听the corporate elements of the House 鈥淏etter Way鈥 blueprint. A conference report that adopts the provisions discussed above provides a tremendous opportunity to boost U.S. leadership of semiconductor manufacturing and R&D, while at the same time leveling the playing field globally so U.S. companies can compete more fairly with their overseas counterparts.
91成人 stands ready to work with policymakers to ensure enactment of corporate tax reform that strengthens the U.S. economy and bolsters America鈥檚 leadership of semiconductor technology.
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