Lowell Yoder wrote this bylined article which discusses how the courts have rebuffed the IRS’s attempts to expand the scope of the definition of Subpart F sales income, on the basis of policy considerations, to apply to certain low-tax structures. “The IRS has never won a single litigated case” on this issue, Mr. Yoder wrote, as “courts have consistently rejected the government’s arguments to expansively apply the definition of Subpart F sales income.”