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Congressional tax writers are largely expected to introduce draft tax legislation sometime next week, Goldman Sachs economists said in a note Thursday, Oct. 26, and the new rules could bring about change for foreign investment.

Some of the substantial changes tax reform is expected to bring forth are "a shift to a territorial tax system, a minimum tax on foreign corporate income, and a one-time tax on untaxed foreign earnings," Goldman wrote. Tax writers should agree to about 25% corporate rate and about a 12% to 15% foreign tax minimum, levied on a global basis.

Of particular interest is the expected tax on "deemed repatriation" of earnings accumulated overseas that haven't yet been taxed in the U.S. Goldman expects those taxes to come in around at least 10% on earnings held in cash and at least 4% on reinvested earnings, with a possibility of a higher rate.

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Goldman said those taxes could generate around $160 billion; however, recent estimates on untaxed foreign earnings that put them close to $3.1 trillion suggest there could be upside to their estimate.

Repatriation isn't likely to have a major impact on foreign investment in the U.S., Goldman said, as unrepatriated earnings here are already "largely available for domestic activities." Without other changes, a lower statutory corporate tax rate will make investing in the U.S. more attractive for foreign firms.

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