arbiter
JournalsAccount

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

Reuven S. Avi-Yonah & Yuri Biondi

Accounting, Economics and Law – A Convivium2025https://doi.org/10.1515/ael-2024-0105article
AJG 2ABDC B
Weight
0.37

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.

1 citation

Open via your library →

Cite this paper

https://doi.org/https://doi.org/10.1515/ael-2024-0105

Or copy a formatted citation

@article{reuven2025,
  title        = {{Legal Form or Unfair Substance? A Symposium Around the Controlled Foreign Company (CFC) Rule}},
  author       = {Reuven S. Avi-Yonah & Yuri Biondi},
  journal      = {Accounting, Economics and Law – A Convivium},
  year         = {2025},
  doi          = {https://doi.org/https://doi.org/10.1515/ael-2024-0105},
}

Paste directly into BibTeX, Zotero, or your reference manager.

Flag this paper

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

Flags are reviewed by the Arbiter methodology team within 5 business days.

Evidence weight

0.37

Balanced mode · F 0.40 / M 0.15 / V 0.05 / R 0.40

F · citation impact0.16 × 0.4 = 0.06
M · momentum0.53 × 0.15 = 0.08
V · venue signal0.50 × 0.05 = 0.03
R · text relevance †0.50 × 0.4 = 0.20

† Text relevance is estimated at 0.50 on the detail page — for your query’s actual relevance score, open this paper from a search result.