Repeal Subpart F Service Income Rules, Practitioners Urge

Overview


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David Noren to make the case that the foreign base company services income rules should at least be modernized if not repealed.