The Resource A comparative perspective of the US controlled foreign corporation rules

A comparative perspective of the US controlled foreign corporation rules

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A comparative perspective of the US controlled foreign corporation rules
Title
A comparative perspective of the US controlled foreign corporation rules
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Subject
Language
eng
Summary
This article provides a comparative perspective on the U.S. subpart F rules by examining the CFC rules of selected countries. The important features of the CFC rules are: the definition of a CFC, the significance of the level of foreign tax on a CFC's income, and the nature of a CFC's income. The rough comparison of the scope of the CFC rules of the nine countries examined here shows convincingly that the U.S. subpart F rules are not noticeably broader than the CFC rules of other countries, with the exception perhaps of the slightly broader concept of base company income under the U.S. rules. Moreover, the analysis shows clearly that it is the Brazilian CFC rules, rather than the U.S. subpart F rules, that are the exception to international norms. The Brazilian rules apply to all of the income of any foreign corporation in which a Brazilian-resident corporation owns 10% or more of the shares irrespective of the amount of foreign tax paid by the foreign corporation on its income. The only two things that the U.S. might seriously consider from the experiences of other countries with CFC rules are a designated jurisdiction approach and a narrower concept of base company income
Citation source
In: Tax law review. - New York. - Vol. 65 (2012),
http://library.link/vocab/creatorName
Arnold, B.J
Language note
English
http://library.link/vocab/subjectName
  • CFC
  • international tax law
  • corporate income tax
  • Subpart F income
Label
A comparative perspective of the US controlled foreign corporation rules
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Publication
Label
A comparative perspective of the US controlled foreign corporation rules
Publication

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