President Obama's May 2009 international tax proposals have sparked a heated debate. Comments have ranged from the pessimistic (Obama's proposals "would . . . reduc[e] U.S. exports as well as business investment and jobs in the United States"); to the optimistic (Obama's proposals would close the loopholes that multinational corporations have been exploiting for years); and to the skeptical (Obama's proposals do not go far enough in fighting the unfairness of the deferral system). Prior to the announcement of these proposals, opposing policy commentators argued vigorously for scrapping the current deferral system all together and adopting either a territorial (i.e., exemption) system or an imputation taxation system.
Samuel C. Thompson Jr., Assessing the Following Systems for Taxing Foreign-Source Active Business Income: Deferral, Exemption, and Imputation, 53 Howard L.J. 337 (2010).