John McDonald


Nowhere is the complexity of the Code more apparent than in the income tax provisions relating to U.S. ownership of foreign corporations.' In fact, the operation of the tax law in this area has become so incredibly complex that many calculations required by the Code can no longer be performed effectively without the use of sophisticated computer software.4 The cost of complying with these Code provisions has started to affect the competitiveness of the corporations to which they apply.5 In fact, there is a definite possibility that our tax laws in this area have become so complex that tax professionals may simply not be able to render accurate advice to their clients.6 In order to determine why this area of the Code is so complex, the nature of the debate raging over the U.S. system of international taxation must first be understood.