In controlled foreign corporation rules, the adoption of the term “participation” both in the definition of control and in the ratable income inclusion rule may cause double taxation. The author considers these rules, and suggests a narrow interpretation of the term “participation” used in the ratable income inclusion rule as “entitlement to profits”.
No takes yet. Share an insight, caveat, or question.
Alexandra Rausch (2024) studied this question.
Synapse has enriched 3 closely related papers on similar clinical questions. Consider them for comparative context: