The Resource The archaic Subpart F services rules: ill-fitting and disruptive for modern services businesses

The archaic Subpart F services rules: ill-fitting and disruptive for modern services businesses

Label
The archaic Subpart F services rules: ill-fitting and disruptive for modern services businesses
Title
The archaic Subpart F services rules: ill-fitting and disruptive for modern services businesses
Creator
Subject
Language
eng
Summary
The authors analyse the Subpart F services rules and demonstrate how these antiquated rules - which have not been updated since the 1960 - are ill-fitting and disruptive for modern services businesses. The authors recommend that the Subpart F category for services income be repealed as part of any international tax reform. While awaiting tax reform, the Treasury and the IRS are urged to eliminate or at least rationalize certain overbroad rules in the regulations that cause many modern business-driven structures to have Subpart F income by deeming the existence of related-person services transactions - these regulatory rules, lacking any basis in the statute, exacerbate the burden of the out-of-date Subpart F services provisions. Treasury and the IRS also should clarify regulatory rules for determining the location of services to address important new issues raised by today's services businesses
Citation source
In: Taxes - the tax magazine. - Riverwoods. - Vol. 94 (2016),
http://library.link/vocab/creatorName
  • Yoder, L.D
  • Noren, D.G
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • Subpart F income
  • services
  • international tax law
  • tax reform
Label
The archaic Subpart F services rules: ill-fitting and disruptive for modern services businesses
Instantiates
Publication
Label
The archaic Subpart F services rules: ill-fitting and disruptive for modern services businesses
Publication

Library Locations

    • IBFD Library AmsterdamBorrow it
      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.3736660 4.9336932
Processing Feedback ...