조세피난처 세제적용의 국제적 과세동향과 그 시사점 - 미국과 일본의 과세실무를 중심으로 -

The benefits reaped from engaging in a tax-avoidance activity have been subject to abuse by resident enterprices through retainig gains in the foreign subsidiariese usually located in the tax havens. In case of korea, it is of recent issue to cope with the International Tax Evasion through Tax Havens. Since It has passed only 10 years since korea introduced CFC legislations, systematic taxation skills and precedent cases have not yet accumulated. also United states which adopted CFC rule first is the second larest country of foreign direct investment on korea's side and many korea-based multinational enterprises are expected to be subject to the US CFC legislation. and for japan, CFC rules are much similar to that of korea's and several cases which can also arrise in korea were judged by the jurisprudence. But previous studies have been only focuced on the study of CFC Rules conducted by comparative analysis of major foreign country's CFC legislations. So in this study we scrutinized US and japan's jurisprudences and taxation systems as well as CFC legislations including the Inversion trasactions which try to evade CFC applications