Repeal Subpart F Service Income Rules, Practitioners Urge


Lowell Yoder told the annual Federal Tax Conference at the University of Chicago Law School it is « discouraging » and “makes no sense” that recent international tax reform proposals to impose a minimum tax on foreign income don’t also propose to repeal the foreign base company services rules, a situation which creates two complex regimes simultaneously. At the conference Mr. Yoder presented a paper he coauthored with partner David Noren to make the case that the foreign base company services income rules should at least be modernized if not repealed.