This paper provides new evidence for the availability A-movement out of a CP and considers its theoretical implications. The discussion concerns what I call the “pseudo”-small clause construction in Japanese, which has not received much attention in the literature. The pseudo-small clause construction shows a puzzling constraint on major subjects originating in complement clauses: the major subjects must receive accusative Case from a matrix predicate despite the availability of nominative Case within the complement clauses. To explain this constraint, it is proposed that (i) pseudo-small clauses are phasal CPs and (ii) the major subjects originating in the pseudo-small clause complements must undergo movement into a matrix theta-position, which takes place across the CP phase. It is also suggested that (i) Tense in Japanese moves to C, (ii) Standard Japanese has null complementizers, and (iii) the ban on A-movement out of a CP is explained in terms of the locality of Agree.