CFCs and the Individual Shareholder

Tax Notes International

H. David Rosenbloom is a Member with Caplin & Drysdale in Washington, director of the international tax program at New York University School of Law, and a member of Tax Analysts’ board of directors. Jaehong Lee is an attorney with Kim & Chang in Seoul.

The authors are grateful to their colleague Josiah Child for his many insightful comments.

In this article, the authors describe how the subpart F and global intangible low-taxed income rules affect the taxation of income of individual shareholders of controlled foreign corporations.

Copyright 2020 H. David Rosenbloom and Jaehong Lee. All rights reserved.

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