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What is Subpart F and why was it created?

International Tax Subpart F Income
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Douglas Stransky
Subpart F (under Internal Revenue Code sections 951-964) was enacted in 1962 in an effort to avoid improperly encouraging foreign investment by U.S. investors. The provisions provide that U.S. investors in controlled foreign corporations will be taxed currently on certain (tainted) undistributed income of such foreign corporations whether or not distributed.
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