Assume you are on the staff of a U.S. Senator from your home state. The Senator is interested in reforming the U.S. tax system, and has asked you for your opinion of the current system for taxing the foreign operations of U.S. companies, as well as potential alternative systems for taxing such income. The Senator is particularly interested in the relative effects of these different systems on U.S. tax revenues and the competitiveness of U.S. companies in foreign markets.
Prepare a two-page memorandum that you could use to brief the Senator on these issues. Make sure that your points are well documented by references to the IRC and other professional sources.