However, Chua said the establishment of the system would be a 'step-by-step' process, starting with addressing the issues of the refunding
structure for exporting firms, as provided under the Tax Reform for Acceleration and Inclusion (TRAIN) Act.
In a refunding issue, the proceeds of a refunding (new) issue are used to retire a refunded (old) issue.
On refundings motivated by debt restructuring, most financial advisors recommend a refunding when it will avoid a default or preclude an unmanageable tax or rate increase.
Offsetting is a collection mechanism statutorily prescribed in section 6402 of the Internal Revenue Code that allows the IRS to apply any overpayment of the taxpayer to an outstanding liability of the taxpayer for any type of tax or any tax period prior to refunding
any balance to the taxpayer.
See Lobel, Refunding
Unconstitutional State Taxes, 52 Tax Notes 581 (July 29, 1991).