Add to ORKGIn this report, Reuven S. Avi-Yonah argues that the dichotomy between active and passive income that underlies subpart F and Notice 98-11 is obsolete, and should be replaced with an explicit link to source tax rates, as most of our trading partners do in similar legislation
The globalization of economic activity, including the expansion of international trade, the amazing ...
Complicated subpart F rules govern the taxation of transactions between a U.S. parent company and it...
This article reviews several familiar plans to alter the structure of taxation, including the flat t...
In this report, Reuven S. Avi-Yonah argues that the dichotomy between active and passive income that...
For the first time since 1913, Congress is considering abandoning the principle that US residents sh...
This article reviews recent US proposals to amend the US Controlled Foreign Corporation (CFC) rules,...
On 29 December 2000, the U.S. Treasury Department released its long-awaited study of Subpart F, enti...
This article explains the history of the Subpart F compromise and of the CTB regime that beleaguers ...
This Note will examine the United States tax treatment of foreign source income, under sections 911 ...
This article responds to the notice of proposed rulemaking under sections 861 and 904 (REG105495-19)...
Prior to the 2017 tax reform (TCJA), with a few exceptions, the United States only taxed the foreign...
Section 904(f) prevents the taxpayers from enjoying the double benefit of deducting foreign source l...
This Note begins with commentary on the United States’ former worldwide system of taxation. This sys...
The globalization of economic activity, including the expansion of international trade, the amazing ...
The immediate U.S. taxation of foreign subsidiaries’ passive, but not active income is a scenario of...
The globalization of economic activity, including the expansion of international trade, the amazing ...
Complicated subpart F rules govern the taxation of transactions between a U.S. parent company and it...
This article reviews several familiar plans to alter the structure of taxation, including the flat t...
In this report, Reuven S. Avi-Yonah argues that the dichotomy between active and passive income that...
For the first time since 1913, Congress is considering abandoning the principle that US residents sh...
This article reviews recent US proposals to amend the US Controlled Foreign Corporation (CFC) rules,...
On 29 December 2000, the U.S. Treasury Department released its long-awaited study of Subpart F, enti...
This article explains the history of the Subpart F compromise and of the CTB regime that beleaguers ...
This Note will examine the United States tax treatment of foreign source income, under sections 911 ...
This article responds to the notice of proposed rulemaking under sections 861 and 904 (REG105495-19)...
Prior to the 2017 tax reform (TCJA), with a few exceptions, the United States only taxed the foreign...
Section 904(f) prevents the taxpayers from enjoying the double benefit of deducting foreign source l...
This Note begins with commentary on the United States’ former worldwide system of taxation. This sys...
The globalization of economic activity, including the expansion of international trade, the amazing ...
The immediate U.S. taxation of foreign subsidiaries’ passive, but not active income is a scenario of...
The globalization of economic activity, including the expansion of international trade, the amazing ...
Complicated subpart F rules govern the taxation of transactions between a U.S. parent company and it...
This article reviews several familiar plans to alter the structure of taxation, including the flat t...