James Tobin, a partner with EY's International Tax Services group, recently authored an article published in BNA's Tax Management International Journal discussing the Base Erosion and Pro?t Shifting (BEPS) proposal in Action 3 for countries to introduce CFC rules, and particularly on the European Union Anti-Tax Avoidance Directive (ATAD), which requires all EU countries, as a minimum standard, to enact CFC rules no later than January 1, 2019.

According to the article, since the United States took the lead in 1962 in enacting Subpart F rules, many countries around the world have followed suit. Presently, more than 35 countries have CFC regimes. The author further notes that the U.S. rules are the most detailed and likely the most complex as written. But by de?nition, all of the countries' rules are complex. Addtionally, given a general lack of signi?cant experience in applying the rules, there are many open questions in almost every country.

This article, published in the July 14, 2017, edition of Tax Management International Journal, is attached below.

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ATTACHMENT

Full text of BNA article