This Note outlines the existing law and practice of the domestic taxation of CFC's in the United States, United Kingdom, France, West Germany, and Japan, each of which exhibits a high level of economic and industrial advancement. United States developments are important because the statutory provisions of Subpart F have been adopted, with modifications, by other nations, including West Germany and Japan. The United Kingdom and France, on the other hand, have not yet adopted an integrated statutory scheme providing for domestic taxation of CFC's. These countries attack tax evasion schemes utilizing foreign controlled companies primarily through general laws, exchange controls, and the requirement of government consent for certain international transactions.
Jamie S. Martin and A. Dale Wilson,
Comparative Analysis of Systems of Domestic Taxation of Controlled Foreign Corporations,
14 Vanderbilt Law Review
Available at: https://scholarship.law.vanderbilt.edu/vjtl/vol14/iss1/4