The Interplay Between Subpart F and the Effectively Connected Income Rules
Bloomberg BNA International Tax Library
Lowell Yoder wrote this bylined article on Subpart F income earned by a controlled foreign corporation (CFC). Mr. Yoder wrote that such income generally does not include U.S.-source income that is effectively connected with the conduct of a trade or business in the United States. This exception does not apply to other U.S.-source income nor does it apply to foreign-source income, even if such income is subject to U.S. taxation.