Marc Gerson discusses the potential impact of a number of the Obama Administration's international tax proposals on private equity firms. With respect to the proposed change in the deductibility of interest expenses allocated to foreign profits, Gerson notes that businesses will have to choose between repatriating their foreign profits earlier than they otherwise would have, or deferring their interest deductions allocated to that foreign income. With respect to the proposed change to the so-called "check-the-box" rules, Gerson notes that "The check-the-box regime primarily allows the foreign group of a US-headed company to move cash on a tax-efficient basis abroad in order to take advantage of different business opportunities. Essentially what [the proposal] does it increases the US tax costs of the foreign operations of a US company, which could have an impact on the competitiveness of those firms, particularly when they're competing against foreign-based companies."