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U.S. Notice 98-11 And The Logic Of Subpart F: A Comparative Perspective, Reuven S. Avi-Yonah
U.S. Notice 98-11 And The Logic Of Subpart F: A Comparative Perspective, Reuven S. Avi-Yonah
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In this report, Reuven S. Avi-Yonah argues that the dichotomy between active and passive income that underlies subpart F and Notice 98-11 is obsolete, and should be replaced with an explicit link to source tax rates, as most of our trading partners do in similar legislation.