On January 2, 2013, President Obama signed into law the 'fiscal cliff' agreement that permanently extends certain 2001 and 2003 tax provisions for individuals. In addition, the legislation retroactively extends, through December 31, 2013, both the CFC look-through rule and the active financing exception to subpart F. Without such retroactive extensions to January 1, 2012, taxpayers could have been subject to subpart F income inclusions during 2012.

