Rep. Tierney introduces bill with "excess return" Subpart F provision

On July 11, 2011, Rep. John Tierney (D-MA) introduced the Tax Equity and Middle Class Fairness Act of 2011 (H.R. 2495), which purports to contribute to deficit reduction by ending many so-called "tax expenditures." This bill is significant primarily because it introduces the first draft statutory language for the Obama Administration's budget proposal on "excess returns" earned by CFCs on outbound transfers of intangible property.