I will be fascinated to learn how much money gets repatriated, with reduced taxation rates under the new law
Here is a liberal source, for the current law, since the resident professional expert will not enlighten the gathered unwashed here.
Urban Institute & Brookings Institute
http://www.taxpolicycenter.org/briefing-book/how-does-current-system-international-taxation-work"How the United States Taxes Foreign-Source Income"
"The federal government taxes US resident multinational firms on their worldwide income at the same rates applied to domestic firms; the current maximum tax rate—the rate that applies to most corporate income—is 35 percent. US multinationals may claim a credit for taxes paid to foreign governments on income earned abroad, but only up to their US tax liability on that income. Firms may, however, take advantage of cross-crediting, using excess credits from income earned in high-tax countries to offset US tax due on income earned in low-tax countries.
US multinationals generally pay tax on the income of their foreign subsidiaries
only when they repatriate the income, a delay of taxation termed “deferral.†Deferral, the credit limitation, and cross-crediting all provide strong incentives for firms to shift income from the United States and other high-tax countries to low-tax countries.
Suppose, for example, a US-based multinational firm facing the 35 percent maximum corporate income tax rate earns $800 in profits in its Irish subsidiary (figure 1). The 12.5 percent Irish corporate tax reduces the after-tax profit to $700. Suppose the firm then repatriates $70 of this profit and reinvests the remaining $630 in its Irish operations. The firm must then pay US tax on a base of $80 (the $70 plus the $10 in Irish tax paid on that portion of its profits), or $28, but it claims a credit for the $10 Irish tax, leaving a net US tax of $18. If the firm has excess foreign tax credits from operations in high-tax countries, it can offset more (or possibly all) of the US tax due on its repatriated Irish profit. Meanwhile, deferral allows the remaining profit ($630) to grow abroad, free of US income tax until it is repatriated."
