On May 11, the Obama Administration (the “Administration”) issued general explanations of its Fiscal Year 2010 revenue proposals, including a number of international tax reform proposals that could have a dramatic impact on multinational businesses and other taxpayers with foreign investments or activities. The proposals provide a more comprehensive look at international tax proposals that had previously been described, including proposals to impose significant constraints on the ability to defer U.S. tax on foreign earnings, tighten limitations on claiming foreign tax credits, and create a wide array of enhanced compliance measures. The Administration also introduced various new international tax proposals.

The following is a summary of the Administration?s international tax proposals. Except as noted below, the proposed changes to the substantive tax rules would be effective for tax years beginning after December 31, 2010, while the effective dates for the various enhanced compliance measures generally depend upon the date of enactment.

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