![Wisconsin budget surplus Wisconsin budget tax proposals Wisconsin property tax system, Wisconsin State Assembly, Wisconsin Committee on Community Development](https://taxfoundation.org/wp-content/uploads/2019/06/madison-wisconsin-300x200.jpg)
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![Wisconsin budget surplus Wisconsin budget tax proposals Wisconsin property tax system, Wisconsin State Assembly, Wisconsin Committee on Community Development](https://taxfoundation.org/wp-content/uploads/2019/06/madison-wisconsin-300x200.jpg)
![U.S. Federal Individual Income Tax Rates History, 1862-2021, U.S. federal historical income tax rates, historical federal tax rates, and historical federal income tax rates income tax rates history tax deductions, regressivity of tax deductions](https://taxfoundation.org/wp-content/uploads/2019/06/tax-compliance-1040-costs-e1561735884922-300x200.jpeg)
The Regressivity of Deductions
3 min read![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)
The Economics Behind Thin-Cap Rules
6 min read![thin-cap rules, thin-capitalization rules, debt-to-equity ratio, safe-harbor rules, debt shifting](https://taxfoundation.org/wp-content/uploads/2019/06/thin-cap-final-292x300.png)
Thin-Cap Rules in Europe
2 min read![vapor taxes 2019, e-cigarette taxes, vape, vaping, vape taxes, vapor taxes, vapor excise taxes](https://taxfoundation.org/wp-content/uploads/2019/02/FINAL-300x287.png)
Vaping Taxes by State, 2019
3 min read![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