OECD/International - The Evolution of Controlled Foreign Corporation Rules and Beyond
- B.J. Arnold
- Bulletin for International Taxation, 2019 (Volume 73), No 12
- 29 November 2019
This article traces the evolution of controlled foreign corporation (CFC) rules, including their compatibility with treaty provisions. It argues that CFC rules would be preferable to the Inclusive Framework proposal on the OECD/G20 Base Erosion and Profit Shifting Project (Pillar Two) for a uniform minimum tax on all CFC income.