Prof. Avi-Yonah proposes a 35 percent withholding tax on deductible payments made to a non-U.S. resident, in coordination with other OECD members. The tax is aimed at U.S. residents posing as foreign investors and would be refundable when the beneficial owner shows that the payments have been reported to tax authorities in the owner’s country of residence.
Avi-Yonah, Reuven S. "A Coordinated Withholding Tax on Deductibility Payments." Tax Notes 119, no. 9 (2008): 993-6.