@“Cardinal Fang”
The deferral of income from controlled foreign corporations is the amount that a US corporation’s nonUS subsidiary has not yet dividended up to it yet. The nonUS sub is not subject to US tax on its nonUS income unless or until it pays a dividend to the US parent (or lends it the $). This amount is what us referred to as “trapped cash”. Companies don’t want to bring their nonUS $ back to the US or it will be taxed.
Most countries never tax the income that a foreign sub makes outside that country, and presume it has already been taxed there. It is the difference between worldwide income tax and territorial tax regimes.
All this nonsense about companies reincorporating outside the US? It is really just making sure the parent of all the nonUS companies in the new company group is NOT a US company so that they don’t have to deal with the issue. If the US would adopt a territorial regime (as every country but one other has), then the US would be on a level playing field as a place of business for big multinationals!!