Whatever Happened to Subpart F? U.S. CFC Legislation after the Check-the-Box Regulations
26 Pages Posted: 2 Dec 2007
The Treasury's adoption of the so-called check-the-box regulations, in 1996, proved to be a very troubling development for international tax policy. This paper explores how the regulations facilitated devices that many multinational U.S. companies have used to divert income into the shelter of tax havens, while steering clear of subpart F. As a result of these devices, subpart F has fallen increasingly short of the goal of curbing tax haven sheltering. The paper suggests that with relatively small changes in the regulations and the subpart F statutes, Congress and the Treasury could go far toward restoring subpart F to its intended scope.
Keywords: international taxation
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