Number: RL32749 Title: U.S. Taxation of Overseas Investment and Income: Background and Issues in 2005 Authors: Donald J. Marples, Government and Finance Division Abstract: One of the chief manifestations of the increased openness of the U.S. economy is an increase in U.S. investment abroad. U.S.-based multinational firms are increasing their overseas operations and U.S. investors are increasing the foreign assets in their portfolios. This report analyzes how the current U.S. tax system applies to foreign investment undertaken by U.S. firms abroad, and how that application was changed by recent legislation. It also assesses the impact of the tax system and legislation, and concludes by discussing a variety of issues in international taxation that Congress may face in 2008 and beyond. It begins with a brief examination of the data on international investment. Pages: 14 Date: May 21, 2008