President’s Budget Would Apply Subpart F to Toll Manufacturing Arrangements


Lowell Yoder, in this bylined article, examined what he called the “shortsighted” Obama Administration proposal to expand the definition and taxation of “foreign base company sales income.” As Mr. Yoder wrote, “Causing income derived by foreign subsidiaries from the manufacture and sale of products to be subject to taxation in the United States – which has the highest tax rate of any industrialized country – puts U.S.-based companies at a competitive disadvantage.” Read the full article