![international debt sharing, debt financing, market value of a firm, lend money](https://taxfoundation.org/wp-content/uploads/2019/06/international-competition-globe-enhaced-e1561651253753-300x200.jpg)
Blog Articles
![international debt sharing, debt financing, market value of a firm, lend money](https://taxfoundation.org/wp-content/uploads/2019/06/international-competition-globe-enhaced-e1561651253753-300x200.jpg)
![opportunity zone effectiveness, opportunity zone benefits, opportunity zone tax break](https://taxfoundation.org/wp-content/uploads/2019/06/opportunity-zone-effectiveness-opportunity-zone-benefits-opportunity-zone-tax-break-e1561559845855-300x200.jpg)
![small business tax relief, small business tax compliance, small business compliance, small businesses](https://taxfoundation.org/wp-content/uploads/2019/06/work-investment-job-economic-impact-300x200.jpg)
![digitalization of the economy, international tax treaty system, OECD digital economy](https://taxfoundation.org/wp-content/uploads/2019/06/flag-international-global-300x240.jpg)
![SALT cap repeal, State and local tax deduction cap repeal (state and local tax cap). Repealing the cap on the State and Local Tax Deduction would be regressive and mainly benefit the wealthy SALT deduction cap, House Ways and Means Committee testimony, impact of limiting SALT deduction, SALT deduction cap, State and Local Tax Deduction cap](https://taxfoundation.org/wp-content/uploads/2019/06/capitol-us-capitol-hearing-event-federal-e1561477935763-300x200.jpeg)
Testimony before the House Ways and Means Select Revenue Measures Subcommittee
Watch Nicole Kaeding, Vice President of Federal and Special Projects at the Tax Foundation, testify before the House Ways and Means Select Revenue Measures Subcomittee on the impact of limiting the SALT deduction.
23 min read![Tax Cuts and Jobs Act offshoring Controlled Foreign Corporation rules around the world CFC rules US CFC rules passive foreign investment companies, PFICs GILTI, global minimum tax](https://taxfoundation.org/wp-content/uploads/2019/06/linkedin-In-Stream_Wide___interntional-global-map-gilti-e1561400252793-300x158.jpg)
How Controlled Foreign Corporation Rules Look Around the World: United States of America
The United States was the first country to enact CFC rules, and it is probably the country with the most complex set of rules that will be presented in this blog series. The rules determine control using a combined ownership test: one for the corporation and the other at the shareholder level. The assessable income under the rules is generally passive income but the amount of foreign income subject to U.S. tax has expanded with the adoption of GILTI.
10 min read![Massachusetts millionaire tax, Massachusetts millionaires' tax amendment](https://taxfoundation.org/wp-content/uploads/2019/06/FINAL-013-300x251.png)
![Maine hotels, Maine campgrounds, Maine food, Maine lobster, Portland Maine, Maine lighthouses](https://taxfoundation.org/wp-content/uploads/2019/06/Maine-lighthouse-e1561044663184-300x168.jpg)
![intellectual property IP tax GILTI FDII global minimum tax Biden tax patent boxes impact business, patent boxes, software, intellectual property tax](https://taxfoundation.org/wp-content/uploads/2019/06/IP-patent-boxe-e1561041263501-300x184.jpeg)
How Patent Boxes Impact Business Decisions
As with every change in tax policy, there are trade-offs. The Modified Nexus Approach adds an additional layer of complexity to the already complex issue of taxing IP income. Linking tax breaks for IP income to its associated R&D activity has changed the game and will likely result in some businesses restructuring and relocating their IP assets and R&D activity. Effective tax rates on IP income will likely play an important role in determining optimal locations, giving measures such as R&D credits more importance. Whether this new approach to IP taxation will impact profit shifting and which countries will be the winners and losers is yet to be seen.
6 min read![OECD global tax deal CFC Rules, OECD CFC, OECD multinational, OECD minimum tax, OECD multinational companies](https://taxfoundation.org/wp-content/uploads/2019/06/international-globe-enhanced-e1560780254911-300x200.jpg)
CFC Rules Around the World
Our paper undertakes a review of controlled foreign corporation (CFC) rules around the world as a contribution to the global discussion over the possible expansion of existing anti-base erosion CFC regimes or the potential adoption of a minimum tax.
3 min read![church parking tax, church tax, nonprofit tax, charity tax](https://taxfoundation.org/wp-content/uploads/2019/06/church-religious-charity-parking-e1560531362720-300x187.jpeg)
In Defense of the “Church Parking Tax”
2 min read![controlled foreign corporation rules](https://taxfoundation.org/wp-content/uploads/2019/02/international1-flag-flags-300x200.jpg)
Ripple Effects from Controlled Foreign Corporation Rules
Governments should recognize these trade-offs as they implement controlled foreign corporation (CFC) rules or change their tax policies in ways that increase taxes on foreign subsidiaries.
7 min read![short-term rental, rent income, hotel, airbnb, rental income](https://taxfoundation.org/wp-content/uploads/2019/06/airbnb-2384737_1920-300x173.jpg)
![Cory Booker renters tax credit affordable housing rent tax credit rent credit](https://taxfoundation.org/wp-content/uploads/2019/06/cory-booker-555-300x200.jpg)
![Martin Feldstein receives the Tax Foundation Distinguished Service Award](https://taxfoundation.org/wp-content/uploads/2019/06/TF_M_Feldstein_1-300x248.png)
Remembering Martin Feldstein
1 min read![Italy income taxes, Italy tax, Italy taxes, Italy income tax, Italy tax reform Italy taxes](https://taxfoundation.org/wp-content/uploads/2019/06/Italy-tax-reform-e1560347902154-300x188.jpg)
Italy Can Pay for a Flat Tax
4 min read![IRS SALT IRS state and local deduction SALT guidance SALT cap workaround charitable deduction SALT workaround](https://taxfoundation.org/wp-content/uploads/2019/06/IRS-e1560289434398-300x200.jpeg)
![Minnesota policymakers Minnesota lawmakers Minnesota state tax conformity Minnesota tax conformity Minnesota tax law Minnesota tax reform](https://taxfoundation.org/wp-content/uploads/2019/06/Minnesota-4-e1560261002695-300x200.jpg)
![New Jersey millionaire's tax Gov. Phil Murphy](https://taxfoundation.org/wp-content/uploads/2019/06/AdobeStock_169801022-e1559930755890-300x196.jpeg)
![arizona lawmakers Arizona income tax cuts Arizona federal conformity Arizona tax cuts](https://taxfoundation.org/wp-content/uploads/2019/06/Arizona-300x200.jpg)