A Comparative Analysis of CFC Regimes in Latin America
17 Pages Posted: 27 Jan 2016
Date Written: December 3, 2012
This paper provides a brief comparative analysis between the Controlled Foreign Corporations rules ("CFCs rules") in Latin American countries and in the United States, the pioneer country in developing this kind of anti-deferral rules in 1962. The author concludes that the effectiveness of the current and future CFC regimes in the Latin America will depend on how countries face the new challenges affecting anti-deferral rules, specifically the characterization of passive and active income under an e-commerce era and the proliferation of hybrid entities.
Keywords: CFC rules, anti-deferral, deferral, U.S. tax law, Latin America, passive income, active income
JEL Classification: K33, K34, H25
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