This disincentive disappears if the corporate tax base is decoupled from current profits and linked to some broad measure of activity. Indeed, this would create an incentive for each company to outperform the average, since above average profits would go untaxed.

Taxes on high premium insurance policies would lead many employees and employers to shift their sources of tax free income from these health insurance benefits to other forms of untaxed compensation. If they do this, the government would not collect the additional revenue from the insurance companies, employers, or employees.

In exchange for shifting to a territorial system and reducing the tax rate, the federal government could tax all of these untaxed past earnings at a low rate to be paid over a ten year period. Companies would then be free to repatriate their pre existing earnings without paying any additional tax, while future foreign earnings could, as in other countries, be repatriated by paying a low 5 tax.