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Since 1994, the trend in the United States and other developed countries appears to be to reduce the scope of residence jurisdiction and increase the emphasis on source jurisdiction. If this trend continues, these countries are likely to move toward territoriality and decrease the emphasis on their CFC rules. In the author’s opinion, the reason for this trend is political and economic, not legal. It is part of tax competition, specifically the competition to be the headquarters jurisdiction for multinationals. The author also thinks, however, that it is not necessary to go down this road because the solution to the competitiveness issue is collaboration, not more competition.


© 2008 Reuven S. Avi-Yonah. Originally published in 62 Bull. Intl. Taxn. 10, pp. 471-474, Journals IBFD. Bulletin for International Taxation is available online at Reproduced with permission.