The Treasury Department and Internal Revenue Service (IRS) have issued final and proposed regulations on the taxation of earnings of controlled foreign corporations (CFCs). The regulations were issued pursuant to Sec. 951(a) of the Internal Revenue Code (IRC), which requires each US shareholder of a CFC to include in income that shareholder's pro rata share of the CFC's Subpart F income and certain other items, including the increased investment of the earnings of the CFC in US property as determined under Sec. 956. The regulations contain rules regarding how each US shareholder's pro rata share of such income is to...