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Copyright (c) 2012 New York University School of Law
Tax Law Review

SYMPOSIUM ON INTERNATIONAL TAXATION AND COMPETITIVENESS: Comparative Perspective on the U.S. Controlled Foreign Corporation Rules

Spring, 2012

New York University Tax Law Review

65 Tax L. Rev. 473




I. Introduction
The purpose of this Article is to provide a comparative perspective on the U.S. subpart F rules by examining the CFC rules of selected countries. The Article might be subtitled, "What, if anything, can the United States learn from the experiences of other countries with CFC rules?" The Article is based on the two panels dealing with controlled foreign corporation ("CFC") rules held during a Conference on International Taxation and Competitiveness sponsored by the American Tax Policy Institute. Some of the panelists produced a brief paper describing the CFC rules of their countries. 1

For many years, claims have been made that U.S. multinationals are at a significant competitive disadvantage compared to many foreign-based multinationals because the U.S. subpart F rules are broader and harsher than the CFC rules of other capital-exporting countries. 2 The analysis in the Article suggests that these claims are unfounded.

At the outset, it is important to register a cautionary note about this comparative analysis. Readers should be skeptical about drawing conclusions from any comparison of discrete aspects of countries' tax systems. Pieces of a tax system can be properly assessed only in the context of the system as a whole. That said, CFC rules are more suitable for comparative analysis than many other types of rules because in all countries CFC rules have the same fundamental purpose and structure. 3

The comparative analysis of the CFC rules of the nine countries examined here is made more difficult because several of ...
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