US Subpart F Legislative Proposals: A Comparative Perspective
Reuven S. Avi-Yonah
University of Michigan Law School
Università degli Studi di Milano-Bicocca; University of Michigan at Ann Arbor
October 30, 2011
U of Michigan Law & Econ Research Paper No. 12-003
U of Michigan Public Law Working Paper No. 264
This article reviews recent US proposals to amend the US Controlled Foreign Corporation (CFC) rules, also known as Subpart F. It places the US debate in a comparative perspective by describing how the US proposals fit in with developments in other countries that have CFC rules.
Number of Pages in PDF File: 24
Keywords: controlled foreign companies, cfc, international taxation, Subpart F
JEL Classification: K34
Date posted: January 27, 2012 ; Last revised: January 31, 2012
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