A Comparative Analysis of CFC Regimes in Latin America

17 Pages Posted: 27 Jan 2016

See all articles by Leopoldo Parada

Leopoldo Parada

University of Leeds School of Law

Date Written: December 3, 2012

Abstract

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

Suggested Citation

Parada, Leopoldo, A Comparative Analysis of CFC Regimes in Latin America (December 3, 2012). Tax Notes International, Vol. 68, No. 10, 2012, Available at SSRN: https://ssrn.com/abstract=2722122

Leopoldo Parada (Contact Author)

University of Leeds School of Law ( email )

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