Trade Associations' Letter on Tax Reform, Treatment of Foreign Earnings

August 11, 2017

The Honorable Steven Mnuchin

Secretary of the Treasury

1500 Pennsylvania Avenue NW

Washington, DC 20220  

Dear Secretary Mnuchin: 

Pro-growth tax reform is a high priority for the undersigned organizations, which collectively represent businesses and taxpayers from every sector of the economy. We appreciate the focus and determination from the Administration as you work with leaders in the House and Senate to advance permanent, comprehensive tax reform. We stand ready to work with your team to ensure its passage. 

We write today to highlight an important issue to all of our organizations—the tax treatment of offshore earnings in moving to a territorial tax system. Specifically, we ask that the transition to a territorial system include a two-rate approach in taxing foreign earnings that distinguishes between short-term cash reserves and income reinvested in other assets. 

Many U.S. multinationals have operated and competed overseas for decades and have reinvested significant capital or have made acquisitions of foreign businesses or other investments. Imposing a significant tax on their overseas assets will reduce the ability of these U.S. global companies to remain competitive. 

Consequently, we support a bifurcated approach that would apply one tax rate to accumulated foreign earnings held passively in cash and cash equivalents and a separate tax rate to accumulated foreign earnings invested in other assets, recognizing that we represent a broad range of industries and the bifurcated rate should be applied fairly to all. 

We also support efforts to allow companies to pay this tax liability over a period of at least eight years with no interest charge. 

Thank you in advance for considering our request. Our organizations look forward to continue working with you and your staff on historic, pro-growth, pro-competitiveness tax reform. 



Aerospace Industries Association

American Chemistry Council

American Coatings Association

American Fiber Manufacturers Association

American Forest & Paper Association

American Fuel & Petrochemical Manufacturers

AMT - The Association For Manufacturing  

Technology Associated Industries of Florida

Associated Industries of Massachusetts

Association of Equipment Manufacturers (AEM) 

Business & Industry Association of New Hampshire

Business Roundtable

California Manufacturers & Technology Association


Consumer Specialty Products Association

Edison Electric Institute

Electronic Components Industry Association

Financial Executives International

General Aviation Manufacturers Association

Georgia Association of Manufacturers

Greater Pittsburgh Chamber of Commerce

Illinois Manufacturers' Association

INDA, The Association of the Nonwoven Fabrics Industry

Information Technology Industry Council

International Housewares Association

Iowa Association of Business and Industry

Metal Powder Industries Federation

Motor & Equipment Manufacturers Association

NAHAD - The Association for Hose & Accessories Distribution

National Association of Manufacturers

National Association of Printing Ink Manufacturers

National Foreign Trade Council

National Taxpayers Union

Nebraska Chamber of Commerce & Industry

New Mexico Business Coalition

Northeast PA Manufacturers & Employers Association

Ohio Chamber of Commerce

Pennsylvania Chamber of Business and Industry

Plastics Industry Association

Plumbing Manufacturers International

Rhode Island Manufacturing Association

Semiconductor Industry Association

Silicon Valley Leadership Group

Society of Chemical Manufacturers & Affiliates (SOCMA)


Technology CEO Council

Tennessee Chamber of Commerce / Tennessee Manufacturers Association

Texas Assn of Manufacturers

Texas Association of Business

The Business Council of New York State, Inc.

The New England Council

U.S. Chamber of Commerce

Valley Industrial Association

Wisconsin Manufacturers & Commerce


cc: The Honorable Mitch McConnell, Senate Majority Leader

The Honorable Paul Ryan, Speaker of the House

The Honorable Orrin Hatch, Chairman, Senate Finance Committee

The Honorable Kevin Brady, Chairman, House Ways & Means Committee

Mr. Gary Cohn - Director, National Economic Council