Repatriated Earnings under Sec. 965: Using the Safe-Harbor Test in 2007 to Ease Compliance Reporting and Protect Tax Benefits.

The article reports on the decision of U.S. multinational corporations to repatriate billions of dollars in earnings from foreign subsidiaries to the U.S. under Section 965 of the American Jobs Creation Act of 2004 during the time such repatriation was allowed. Section 965 aims to encourage companies to repatriate those accumulated earnings in order to strengthen their domestic operations and stimulate the economy. Section 965(b)(4)(B) contains general rules as to the categories of expenditures that qualify as permitted investments.