The Archaic Subpart F Services Rules: Ill-Fitting and Disruptive for Modern Services Businesses

In Depth


Lowell Yoder and David Noren wrote this bylined article analyzing the Subpart F services rules and demonstrating how those outdated rules are ill-fitting and disruptive for modern services businesses. The authors provided guidance for applying these antiquated rules to modern services arrangements and suggested ways the IRS and Treasury should update the rules to make them more workable with today’s services businesses.