According to its annual Article IV consultation report for the US, the current corporate tax structure is too complex...and incentivises a range of cross-border avoidance and tax planning mechanisms to lower US tax liabilities. The report states: ‘Reform of the corporate income tax is badly needed and could help revitalize business dynamism and investment. In addition to rate reduction and a streamlining of business tax expenditures, tax avoidance opportunities should be reduced by tightening income-stripping rules through limits on interest deductions'...There should also be a mandatory tax on the existing stock of un-repatriated, foreign-sourced earnings (with payment spread over the next several years).