In this article, Marc Gerson and Rocco Femia focus on two of the proposed changes to the U.S. taxation of U.S.-based multinationals: first, the deferral of deductions otherwise allowable to a U.S. taxpayer to the extent such deductions are allocated to un-repatriated income earned by the taxpayer’s controlled foreign corporations; and second, a limitation on foreign tax credits based on an average foreign tax rate imposed on the sum of the foreign source income of the taxpayer and the un-repatriated income earned by the taxpayer’s CFCs.