Overview
Lowell Yoder, appearing with a senior IRS counsel at an International Tax Institute meeting focused on the application of subpart F rules to intragroup services, noted that many taxpayers take the position that if the services are performed by a company under contract, the people of a controlled foreign corporation (CFC) are not deemed to be performing them. In that case, the rules are unclear whether the CFC must use its own personnel or whether another company’s employees count as CFC people.
