Download This PaperWhirlpool: Law or Policy?
176 Tax Notes Federal 959 (2022)
13 Pages Posted: 29 Sep 2022
Date Written: August 2022
Abstract
This article argues that while two U.S. courts reached the desirable policy result in the Whirlpool case, their conclusion that the foreign base company sales income branch rule of subpart F of the Code applies not only to sales branches but also to manufacturing branches is inconsistent with the statutory text.
Keywords: Subpart F, foreign base company sales income, FBCSI, branch rule, sales branch, manufacturing branch
JEL Classification: K34
Suggested Citation: Suggested Citation
Shaheen, Fadi, Whirlpool: Law or Policy? (August 2022). 176 Tax Notes Federal 959 (2022), Available at SSRN: https://ssrn.com/abstract=4228064
Fadi Shaheen (Contact Author)
Rutgers, The State University of New Jersey - School of Law, Newark ( email )
Newark, NJ
United States
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