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Originally published in Tax Notes International, this article examines The Tax Court of Canada's CIT judgment, as well as two pending companion cases, sheds light on how the simple notion underlying controlled foreign corporation attribution rules— that CFCs' undistributed passive income should be taxed as earned — can evolve into complex, mechanical, and sometimes convoluted rules.
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Originally published in Tax Notes International, this article
examines The Tax Court of Canada's CIT judgment, as well as two
pending companion cases, sheds light on how the simple notion
underlying controlled foreign corporation attribution rules—
that CFCs' undistributed passive income should be taxed as
earned — can evolve into complex, mechanical, and sometimes
convoluted rules.
The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.
