I am particularly happy to participate in this important conference at The George Washington University School of Law. I feel as though I am caught in the middle of bipolar, policy approaches to international tax, championed by two outstanding George Washington Law School professors of international tax, Professor Robert Peroni and Professor Karen Brown. Professor Peroni has argued persuasively that the United States should end deferral, a policy under which U.S.-controlled foreign corporations (CFCs) are generally not subject to U.S. taxation until the earnings are distributed, essentially by adopting the partnership model for taxing the foreign source income of CFCs.
Samuel C. Thompson Jr., The Case for Tax Sparing Along with Expanding and Limiting the Subpart F Regime, 35 Geo. Wash. Int'l L. Rev. 303 (2003).