American corporations have more than a trillion dollars U.S. held offshore, in part because of the 35 percent tax rate that money would be subject to only when it is repatriated. Apple alone has more than $100 billion outside the U.S., and the company has borrowed money from bond markets in the U.S. and Europe rather than pay the repatriation tax.
No agreement has been reached, but Reuters reported that consensus is building for a new holiday based in part on the needs of the Highway Trust Fund. The last corporate tax holiday was in 2004, when U.S. companies were allowed to repatriate money for just 5.25 percent.
The results of that tax holiday have played a role in their not being another since. It was billed at the time as a way for U.S. companies to bring money back to the U.S. so that they could invest it in new opportunities. In reality, almost all of the money was used in stock buybacks and stock dividends, rather than reinvestment, and the effort was viewed as an exercise to enrich investors rather than the U.S. as a whole.
Reuters was short on specifics, but one way of dealing with that aspect of a tax holiday would be to pair the holiday with caps placed on interest deductions so that the U.S. Treasury would see a net gain on the deal. In the end, the need to infuse the U.S. Highway Trust Fund without raising taxes—an impossibility in the current political climate in the U.S.—may be the deciding factor.