This article explains the history of the Subpart F compromise and of the CTB regime that beleaguers its application. The paper then evaluates whether Subpart F as an independent system is capable of affecting the policy goals behind its creation. Subsequently, this paper analyzes what is the most prudent and economically sound course of action for healing the U.S. international taxation system. Namely, at issue is whether additional regulation, in the form of a re-vamped Subpart F or a scaled-down CTB, would solve the ailments, or whether the complete revocation of existing policies, such as the U.S. semi-worldwide taxation system or the CTB regime, is necessary. Finally, the paper concludes that the evolution of Subpart F has come full circle. In light of current inversions of major U.S. multinationals into non-U.S. multinationals, specifically to avoid the complications of Subpart F, and of the reduction of the U.S. tax base that necessarily corresponds, Subpart F undeniably results in some erosion of the U.S. tax base. Its purpose for existing is thus nullified and it is time for the U.S. to return to a policy of territorial taxation.

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