The current tax policy of the federal government suggests that in the future, more capital will be shifted from Germany to abroad, rather than less. This makes the taxation of foreign income increasingly relevant and significant. A system-compliant regulation that has long been demanded would be appropriate, but is hardly to be expected. By referring to the tax-systematic intention of the foreign income taxation, this work demonstrates the tax effects of the current legal situation in Germany and the USA. In light of previous German reform efforts, alternative designs for future foreign income taxation are examined. The analysis concludes with the development of a tax-systematic design recommendation for the legislator.