Today, as part of its work on base erosion and profit shifting (BEPS), the OECD released a discussion draft addressing rules for controlled foreign companies (CFCs).  The draft addresses policy considerations relevant to designing CFC rules, such as how to balance the need to tax foreign income and the need to maintain competitiveness, limit administrative and compliance burdens, and avoid double taxation.  The draft then considers the following seven “building blocks” necessary for effective CFC rules: (1) definition of a CFC; (2) threshold requirements; (3) definition of control; (4) definition of CFC income; (5) rules for computing income; (6) rules for attributing income; and (7) rules to prevent or eliminate double taxation.