One concept the CFC regime implements to stop the deferral is Subpart F. Under the Subpart F provision, certain types of income (also referred to as Subpart F income) earned by a CFC are taxable to the CFC's U.S. shareholders in the year earned even if the CFC does not distribute the income to its shareholders in that year. Subpart F operates by treating the shareholders as if they had actually received the income from the CFC.

What are some ideas for a new concept could replace the existing Subpart F provision? Why would this concept be a good one to replace the existing one?