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.
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.
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