The Resource CFC regimes for financial services : a quick world tour of approaches by other jurisdictons and the future of the U.S. AFE in a territorial system

CFC regimes for financial services : a quick world tour of approaches by other jurisdictons and the future of the U.S. AFE in a territorial system

Label
CFC regimes for financial services : a quick world tour of approaches by other jurisdictons and the future of the U.S. AFE in a territorial system
Title
CFC regimes for financial services : a quick world tour of approaches by other jurisdictons and the future of the U.S. AFE in a territorial system
Creator
Subject
Language
eng
Summary
The likelihood of fundamental tax reform by the 115th Congress is higher than the last several Congresses. In a more traditional reform or the Blueprint DBCFT (destination based cash flow system), there will likely remain a desire to tax currently in the United States "truly passive" income earned by CFCs. It bears keeping in mind that the current AFE (active financing exception) is not a financial service give away, rather it attempts to level financial services with other industries that have had less administratively burdened active business exceptions in Subpart F since 1962
Citation source
In: International tax journal. - Riverwoods. - Vol. 43 (2017), no. 3 (May-June) ; p. 39-66
http://library.link/vocab/creatorName
Gaffney, M
Geographic coverage
  • North America
  • European Union
  • Europe
  • Asia
Language note
English
http://library.link/vocab/subjectName
  • CFC
  • financial services
  • territoriality principle
  • tax reform
  • Subpart F income
Label
CFC regimes for financial services : a quick world tour of approaches by other jurisdictons and the future of the U.S. AFE in a territorial system
Instantiates
Publication
Label
CFC regimes for financial services : a quick world tour of approaches by other jurisdictons and the future of the U.S. AFE in a territorial system
Publication

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