The introduction of CFC rules and the attempts to reform the ALS aim
at functional conversion. The reinterpretation of the fundamental building
blocks of the DTA regime had the goal of moving closer to taxing different
entities of a multinational group in a more consolidated fashion than
was acceptable under the traditional understanding. In both cases the results
were merely incremental changes to the original concepts. Actors
took great care to subsume the new understandings under the traditional
notions, exercising what can be termed rule stretching.