Separate from the FY2012 budget resolutions, the “Tax Fairness and Simplifi cation Act of 2011” was introduced in the Senate. The proposed tax reform bill would reduce the corporate tax rate to a fl at 24 %. The bill would offset the proposed rate reductions by repealing various tax credits, deductions, exclusions, and preferences. Proposed business revenue offsets include repeal of deferral for active income of controlled foreign corporations, repeal of deferral on active fi nancing income, repeal of the domestic manufacturing deduction, and repeal of the depreciation of equipment in excess of alternative minimum depreciation.