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In 2021, there are reportedly 2,755 billionaires on Earth, with an estimated total net worth of $13.1 trillion. Every year the newspaper Forbes conducts the list of World Billionaires, but we need to acknowledge that, not all billionaires and their wealth gets reported. Usually, the net worth is reported by calculating the number of stocks with the number of shares that the person owns. We take into consideration that the number we see in the newspaper exists only on paper, but the amount of money in the bank account of Billionaire does, not reflect that kind of wealth in any shape and form. Paper wealth differs from “real” or actual wealth, which is the value of the physical assets that are at the disposal of an individual or company. Many individuals and corporations fall victim to the paper wealth trap. On paper, it looks as though the assets logged are worth a certain amount, but the real assets in hand do not add up to the same. In order to assess, the real wealth individual has to realize the asset in the market by selling the asset mentioned below. If the taxpayer sells these assets, it has accumulated capital gains, then the taxpayer is subject to capital gains taxes. By using the tax planning strategy “Buy, Borrow, and Die” the wealthy individual avoids paying the capital gain tax on the assets that they have. This principle suggests buying and holding assets as they appreciate tax-free, as well borrow using the assets as leverage and using debt to reduce or eliminate income and estate taxes, and maximize aftertax wealth accumulation, as well after the taxpayer pass away the heirs, sell the whole wealth is tax-free, and the debt is paid with the tax-free proceeds.

I Inrtoduction2018 marks a century of deviation from a very predominant era of tax legislation in the United States. Through the Revenue Act of 1918, the U.S. Congress enacted a [...], For the first time since 1913, and as part of the 2017 tax reform, Congress adopted a tax regime that exempts from U.S. taxation dividends from foreign subsidiaries. By doing so, Congress abandoned the general principle that U.S. residents should be subject to tax on all income 'from whatever source derived.' This shift marks a good opportunity for considering the reasons the United States taxed such dividends in the first place. In 1962, Congress enacted 'Subpart-F,' which subjected certain earnings of the foreign subsidiaries of American parent corporations to current-base taxation. This was a deviation from the general tax principle of tax deferral, under which earnings of foreign subsidiaries are taxed only upon repatriation of these earnings. An example of a taxable instance would be by a dividend. The new legislation was the result of political compromise. Although the Department of the Treasury (Treasury) supported a wide-scale elimination of tax deferral, Congress eventually adopted a much narrower law which eliminated tax deferral only in instances where it was abused, such as when deferrals are used to avoid paying otherwise owed U.S. taxes.Seven internal Treasury Department reports found in the archives of Harvard Law School's Law Library reveal the dramatic sequence of events that led to the enactment of Subpart-F, one of the most prominent international tax reforms the United States has ever known. The reports unequivocally support the notion that Subpart-F was initially formed mainly due to the deteriorating U.S. Balance of Payment position, and that its 'original intent,' as designed by its main architect, Assistant Secretary of the Treasury, Stanley S. Surrey, was to eliminate tax deferral and protect the U.S. tax base. This was based on the principles of equity, efficiency (Capital Export Neutrality), and elegance. Congress, on the other hand, rejected the proposal and adopted a much narrower piece of legislation, mainly due to the concern that eliminating tax deferral would result in a competitive disadvantage to American corporations operating abroad.Based on the reports, as well as the controlling legal and economic concepts of the time, I argue that Congress was mistaken in limiting the original proposal to eliminate tax deferral. This mistake was the result of relying on overly-emphasized and exaggerated competitive concerns, rather than on concrete and sound tax and fiscal policies.Keywords: International Tax, Tax Policy, Tax Reform, Tax Deferral.JEL Classification: D63, E61, E62, F42, H21, H25, H26, K34, 038.