Deferral of U.S. tax on international income: End it, don't mend it-why should we be stuck in the middle with Subpart F

This article discusses Keith Engel's "Tax Neutrality to the Left, International Competitiveness to the Right, Stuck in the Middle with Subpart F" (2001). In the end, having presented 2 sets of proposals that move in completely opposite directions, Engel offers little real guidance as...

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Bibliographic Details
Published inTexas law review Vol. 79; no. 6; p. 1609
Main Author Peroni, Robert J
Format Journal Article
LanguageEnglish
Published Austin University of Texas, Austin, School of Law Publications, Inc 01.05.2001
Subjects
Big Five accounting firms
Controlled foreign corporations
Corporate income tax
Earnings
Economic activity
Foreign source income
Foreign subsidiaries
Income taxes
International taxation
Law
Multinational corporations
Neutrality
Passive foreign investment companies
Personal holding companies
Proposals
Repatriation
Stockholders
Tax legislation
Tax reform
Taxation
Taxpayers
Transfer pricing
United States > US
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Summary:This article discusses Keith Engel's "Tax Neutrality to the Left, International Competitiveness to the Right, Stuck in the Middle with Subpart F" (2001). In the end, having presented 2 sets of proposals that move in completely opposite directions, Engel offers little real guidance as to which direction Subpart F should move, characterizing that question as "ultimately political."
ISSN:0040-4411
1942-857X