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S. Avi-Yonah argues that the dichotomy between active and passive income that underlies subpart F and Notice 98-11 is obsolete, and should be replaced with an explicit link to source tax rates, as most of our trading partners do in similar legislation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 Joint Committee on Taxation of the U.S. Congress issued a three-volume study in April 2001 entit...
To prevent negative effective tax rates in a territorial system, a multinational corporation’s deduc...
In the new version of his Stop Tax Haven Abuse Act, Sen. Carl Levin, D-Mich., once again proposed to...
In this report, Reuven S. Avi-Yonah argues that the dichotomy between active and passive income that...
This article reviews recent US proposals to amend the US Controlled Foreign Corporation (CFC) rules,...
For the first time since 1913, Congress is considering abandoning the principle that US residents sh...
Complicated subpart F rules govern the taxation of transactions between a U.S. parent company and it...
This article explains the history of the Subpart F compromise and of the CTB regime that beleaguers ...
When a U.S. person conducts business or investment activity abroad through a foreign corporation in ...
The international tax reform proposal introduced by Sen. Max Baucus (D-MT) on November 19, 2013 cont...
The debate about whether to abolish deferral or to adopt territoriality has been going on ever since...
This Note begins with commentary on the United States’ former worldwide system of taxation. This sys...
The article explains the structure of the international tax regime and offers suggestions for improv...
Kahn argues that a 1986 amendment to section 707 invalidated several regulatory provisions promulgat...
Until 1993, the United States led the rest of the developed world in strengthening residence-based w...
The Joint Committee on Taxation of the U.S. Congress issued a three-volume study in April 2001 entit...
To prevent negative effective tax rates in a territorial system, a multinational corporation’s deduc...
In the new version of his Stop Tax Haven Abuse Act, Sen. Carl Levin, D-Mich., once again proposed to...
In this report, Reuven S. Avi-Yonah argues that the dichotomy between active and passive income that...
This article reviews recent US proposals to amend the US Controlled Foreign Corporation (CFC) rules,...
For the first time since 1913, Congress is considering abandoning the principle that US residents sh...
Complicated subpart F rules govern the taxation of transactions between a U.S. parent company and it...
This article explains the history of the Subpart F compromise and of the CTB regime that beleaguers ...
When a U.S. person conducts business or investment activity abroad through a foreign corporation in ...
The international tax reform proposal introduced by Sen. Max Baucus (D-MT) on November 19, 2013 cont...
The debate about whether to abolish deferral or to adopt territoriality has been going on ever since...
This Note begins with commentary on the United States’ former worldwide system of taxation. This sys...
The article explains the structure of the international tax regime and offers suggestions for improv...
Kahn argues that a 1986 amendment to section 707 invalidated several regulatory provisions promulgat...
Until 1993, the United States led the rest of the developed world in strengthening residence-based w...
The Joint Committee on Taxation of the U.S. Congress issued a three-volume study in April 2001 entit...
To prevent negative effective tax rates in a territorial system, a multinational corporation’s deduc...
In the new version of his Stop Tax Haven Abuse Act, Sen. Carl Levin, D-Mich., once again proposed to...