The Resource How OECD BEPS Action 3 would strengthen CFC rules

How OECD BEPS Action 3 would strengthen CFC rules

Label
How OECD BEPS Action 3 would strengthen CFC rules
Title
How OECD BEPS Action 3 would strengthen CFC rules
Creator
Subject
Language
eng
Summary
The OECD issued a public discussion draft on 12 May 2015, that aims to strengthen controlled foreign company (CFC) rules. The OECD took this action as part of the agenda regarding base erosion and profit shifting (BEPS) Action 3 (strengthen CFC Rules). These CFC provisions generally serve as an anti-deferral regime to preclude taxpayers from shifting operating income to tax havens. The authors conclude that while Subpart F has a heavy influence on OECD CFC rules, U.S. taxpayers should not take a victory lap regarding this overlay. Rather, the OECD rules provide an introspective approach more thorough than Subpart F. In particular, the OECD CFC rules expand the Subpart F provisions, especially as to "control" definitions, possibly leading to an integration of the CFC rules with the transfer pricing provisions
Citation source
In: Journal of international taxation. - New York. - Vol. 26 (2015),
http://library.link/vocab/creatorName
  • Feinschreiber, R
  • Kent, M
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • BEPS Project (OECD)
  • CFC
  • Subpart F income
  • control
Label
How OECD BEPS Action 3 would strengthen CFC rules
Instantiates
Publication
Label
How OECD BEPS Action 3 would strengthen CFC rules
Publication

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