Document Type
Article
Disciplines
International Law
Abstract
The Connecticut State Department of Revenue Services issued a declaratory ruling1 in March of 1987 stating that Subpart F income does not qualify as a dividend within the language of the Connecticut Corporation Business Tax.' In issuing this declaratory ruling, the Department reversed its previously stated position that "Subpart F income . ..received from foreign corporations should be treated as dividends "'
This recent development briefly examines whether the federal treatment of Subpart F income as a constructively received dividend requires Connecticut to similarly treat such income for state taxation purposes. It begins with a discussion of the conditions prior to the implementation of Subpart F and its effect once implemented. It then examines the Connecticut Corporation Business Tax4 and its treatment of Subpart F income and addresses some constitutional concerns accompanying taxation of this undistributed income. The recent development concludes that Subpart F income is treated as a dividend for constructive repatriation purposes at the federal level only and is not deductible pursuant to the Connecticut Corporation Business Tax.
Recommended Citation
Santos, Carlos M., "Subpar F Income Under the Connecticut Corporation Business Tax" (1988). Connecticut Journal of International Law. 58.
https://digitalcommons.lib.uconn.edu/cjil/58
Accessibility Requirements
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