A Proposal for Equal Enforcement of the (AET) Accumulated Earnings Tax
11 Pages Posted: 3 Jan 2016 Last revised: 4 Jan 2016
Date Written: May 1, 2015
In this article, Bogenschneider uses the history of the accumulated earnings tax (AET) and its underlying policy justifications as a backdrop for examining the IRS’s current enforcement practice, which effectively exempts U.S. multinationals from the AET. He concludes that the AET could be applied as a backup controlled foreign corporation rule, in lieu of subpart F, against any unreasonable corporate accumulations of earnings in foreign affiliates.
Keywords: 531, AET, accumulated earnings tax
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