U.S. Notice 98-11 and the Logic of Subpart F: A Comparative Perspective

Authors

Reuven S. Avi-Yonah, University of Michigan School of LawFollow

Document Type

Article

Publication Date

1998

Abstract

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S. Avi-Yonah argues that the dichotomy between active and passive income that underlies subpart F and Notice 98-11 is obsolete, and should be replaced with an explicit link to source tax rates, as most of our trading partners do in similar legislation.

Comments

Reprinted with the permission of Tax Analysts

Recommended Citation

Avi-Yonah, Reuven S. "U.S. Notice 98-11 and the Logic of Subpart F: A Comparative Perspective." Tax Notes International 16 (1998): 1797.