Subpart F: Revised Active Rents and Royalties Exception

Overview


Lowell Yoder wrote this bylined article on revised temporary regulations providing that only activities of a controlled foreign corporation’s own employees can be used to account for all active business tests under Subpart F and that cost sharing arrangements cannot be relied on to satisfy the active business tests. “One favorable clarification provides that activities can be conducted in multiple countries for purposes of satisfying the active marketing test,” Mr. Yoder wrote.