In February, 2012, the Treasury and White House unveiled President Obama's Framework for Business Tax Reform. A major proposal was to abolish the deferral on income earned by foreign subsidiaries of U.S. corporations ("CFCs").
Avi-Yonah, Reuven S. "Symposium on International Taxation and Competitiveness: Introduction and Overview." N. Sartori, co-author. Tax L. Rev. 65, no. 3 (2012): 313-22.