24 Pages Posted: 27 Jan 2012 Last revised: 31 Jan 2012
Date Written: October 30, 2011
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.
Keywords: controlled foreign companies, cfc, international taxation, Subpart F
JEL Classification: K34
Suggested Citation: Suggested Citation
Avi-Yonah, Reuven S. and Sartori, Nicola, US Subpart F Legislative Proposals: A Comparative Perspective (October 30, 2011). U of Michigan Law & Econ Research Paper No. 12-003; U of Michigan Public Law Working Paper No. 264. Available at SSRN: https://ssrn.com/abstract=1991966 or http://dx.doi.org/10.2139/ssrn.1991966