
A Conference Sponsored by the American Tax Policy Institute
Washington, DC, October 17, 2011
Organized by Reuven Avi-Yonah and Jane Gravelle
Panel One
The Meaning of “Competitiveness” and “Competitive Disadvantage”,
Jane Gravelle (CRS)
Comparing Subpart F with the CFC rules of other countries,
Brian Arnold (moderator)
The French CFC Regime
Daniel Gutman (Professor at Sorbonne Law School, Partner at CMS Bureau Francis Lefebvre)
Francois Meziane (Lawyer at CMS Bureau Francis Lefebvre)
General features of German CFC Rules
Friedhelm Jacob (Frankfurt am Main, Germany)
Germany's Tax Regime – a hybrid between territorial and worldwide
Friedhelm Jacob (Frankfurt am Main, Germany)
Subpanel B: America and Asia
China’s Controlled Foreign Corporation (CFC) Rules
Tizhong Liao (State Admin of Taxation, PRC)