Abstract
The purpose of this article is to explore means by which the originally-intended function of subpart F could be reclaimed from the inroads allowed by the check-the-box regulations. The article is not intended to contribute to the growing literature on whether U.S. tax policy should be to broaden or narrow the scope of subpart F. The Treasury, in adopting the check-the-box regulations, did not intend to alter the policies reflected in subpart F. My purpose in this article is only to determine whether the balance between deferral and current taxation, unintentionally upset by the regulations, may feasibly be restored.
Recommended Citation
Lokken, Lawrence
(2006)
"Whatever Happened to Subpart F? U.S. CFC Legislation After the Check-the-Box Regulations,"
Florida Tax Review: Vol. 7:
No.
1, Article 15.
Available at:
https://scholarship.law.ufl.edu/ftr/vol7/iss1/15