CFC rules were contested domestically. US businesses and the Republican
opposition in Congress argued that American MNEs would suffer a
competitive disadvantage vis-`a-vis their foreign competitors, who could
continue to shelter their income from taxation. As a compromise solution
the rules that were finally implemented singled out a particular type
of income likely to be diverted to tax havens, namely passive income
(Engel, 2001: 1527–8). The US promoted this legislation within the OECD.
In 1987 the OECD suggested that unilateral anti-avoidance measures be
introduced in all of its member countries, and that the effectiveness of
these measures be supported through increased multilateral information
exchange (Eden and Kudrle, 2005: 115–17). Today nearly all major capital
exporting nations have passed similar legislation. In the process, all
have experienced opposition from corporate capital, claiming that too
strict rules would endanger a country’s competitiveness (Picciotto, 1992:
144–46).