Tax accounting considerations related to lapsing Subpart F provisions

| November 2011

Overview

On December 31, 2011, two favorable Subpart F provisions presently enacted under the U.S. federal tax law will expire:

  • Look-through treatment of payments between related controlled foreign corporations
  • Exceptions for certain active financing income

Multinational companies should consider the effect the scheduled expiration of these provisions may have currently on the measurement of deferred taxes and indefinite reinvestment assertions.

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David Wiseman
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