Recently, a number of lawmakers have proposed additional limitations on deferral to fund other legislative priorities or to address perceived “loopholes” associated with the current subpart F rules. Furthermore, President Obama’s budget “blueprint” included an international tax reform line item that includes reforming deferral, without providing any further detail. Given this budgetary and political environment, it seems likely that subpart F will be “in play” in the 111th Congress. The purpose of this article is to provide some context so that any discussion or debate of subpart F proposals has the benefit of recent legislative history.  This article was co-authored by Rocco Femia and Marc Gerson.