President Obama clarified his proposed international tax reforms.  The President’s proposals would become effective in 2011 and raise a projected $210 million for the Federal government.  Highlights include:

• reformation of the so-called “check-the-box rules” as they apply to foreign entities
• reformation of the foreign tax credit so foreign income and the foreign tax credit are always matched
• deferral of U.S. tax deductions for expenses related to deferred foreign income
• reformation of the foreign tax credit so residual U.S. tax is determined on an average, or pooled, basis