At the core of Obama's "grand bargain for middle-class jobs" is a one-time fee on foreign earnings.

Wait, don't leave!

This policy actually gets to one of the most interesting and difficult problems in tax reform: What do you do with the $1.5-2 trillion in foreign earnings that's sitting overseas because corporations don't want to pay American tax rates?

The business community's favored solution is a "repatriation holiday." That's when Congress temporarily cuts taxes for corporations bringing money back from overseas. We did this in 2004, and corporations have spent millions and millions of dollars lobbying Congress and the White House to do it again. But so far, they've failed -- in part because the evidence shows repatriation doesn't do much for jobs, even as it costs billions.

Both the White House and House Republicans have settled on a different solution: A small, one-time fee on all deferred foreign earnings. This isn't a tax cut for money corporations bring back. It's a levy on all the money they have sitting overseas, and they pay it whether they bring it back or not. After paying the fee, that money is free and clear so far as the taxman is concerned -- corporations can bring it back, leave it overseas, or set it on fire.

The difference between the White House and the House Republicans is how they spend the money. House Republicans use it to further lower corporate tax rates -- a move the White House considers irresponsible, as that's one-time money being put toward a recurring cost, and it'll open up a deficit hole in the future. The White House wants to use the money to finance a bunch of one-time investments in job creation, including a $50 billion infrastructure surge -- a move Republicans consider anathema, as it's a tax increase that's going toward new spending.

Either option, however, presents the same quandary: What happens to the foreign money American corporations make after the one-time fee? This isn't, after all, an ideal long-term solution.

Which is why both the White House and the House Republicans only see this fee happening in the context of a broader corporate tax reform deal that includes a complete overhaul of how we tax foreign earnings -- the White House wants a global minimum tax, and House Republicans want to leave foreign earnings alone. Either way, both sides want an end to this period, in which corporations are holding trillions overseas while they wait for a better deal that they have every reason to believe is on its way.