Once More, With Feeling: TRA 17 And Original Intent of Subpart F

Authors

Reuven S. Avi-Yonah, University of Michigan Law SchoolFollow
Nir Fishbien, University of Michigan Law SchoolFollow

Document Type

Article

Publication Date

11-2017

Abstract

For the first time since 1913, Congress is considering abandoning the principle that U.S. residents should be subject to tax on all income “from whatever source derived.” Specifically, the proposed tax reform legislation, the Tax Cuts and Jobs Act, would completely exempt from U.S. taxation dividends from controlled foreign corporations. This is therefore a good occasion for considering the reasons we tax those dividends in the first place.

Comments

Reprinted with the permission of Tax Analysts.

Recommended Citation

Avi-Yonah, Reuven S., co-author. "Once More, With Feeling: TRA 17 and Original Intent of Subpart F." N. Fishbien, co-author. Tax Notes 157, no. 7 (2017): 959-70.