The last half-century has seen a phenomenal increase in the volume and complexity of international business. Today's global economy allows multi-nationals to design their operations in a manner that may significantly reduce their taxes, particularly by taking advantage of tax incentives offered by many countries to attract geographically-mobile capital and activities. Since 1962, 19 countries have enacted specific statutory regimes to counteract the perceived abuse of controlled foreign companies (CFCs) located in tax havens. In three cases to date, CFC legislation has been challenged in...