Legal Form or Unfair Substance? A Symposium Around the Controlled Foreign Company (CFC) Rule

Avi-Yonah Reuven S. and Yuri Biondi
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Avi-Yonah Reuven S.: University of Michigan, Ann Arbor, MI, USA

Accounting, Economics, and Law: A Convivium, 2025, vol. 15, issue 2, 271-274

Abstract: This symposium around the case of the Controlled Foreign Company (CFC) rule offers to CONVIVIUM readers a debate which saw both authors stalling in their respective positions. On the one side, the negative taxation principle under which ‘tax avoidance is acceptable under the law;’ on the other side, the positive taxation principle that ‘all and every citizens shall pay a fair share of taxation.’ Their discussion certainly raises important matters for the current state of affairs in tax law and regulation, but it does not provide any explicit solution for issues which were raised. In this context, readers may aim at learning from both authors.

Keywords: international tax avoidance; controlled foreign company; substance over form (search for similar items in EconPapers)
JEL-codes: H26 K34 (search for similar items in EconPapers)
Date: 2025
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DOI: 10.1515/ael-2024-0105

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Accounting, Economics, and Law: A Convivium is currently edited by Reuven S. Avi-Yonah, Yuri Biondi and Shyam Sunder

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