CFCs
The IRS issued proposed regulations providing that Sec. 956, which requires an income inclusion by U.S. shareholders of controlled foreign corporations (CFCs) that invest in U.S. property, should not apply to corporate shareholders.
This article discusses the GILTI regime and the rules in proposed regulations and some of the most notable implications.
The proposed regulations effectively treat a consolidated group as a single entity for purposes of determining the sharing of tested loss.
The IRS issued proposed regulations implementing Sec. 951A’s global intangible low-taxed income provision, which requires a US shareholder of a controlled foreign corporation to include this income in the shareholder’s gross income.
The shift to a territorial system was designed to help dissuade U.S. companies from moving profits overseas, but it may make the practice more rewarding instead.
The IRS issued proposed regulations providing that Sec. 956, which requires an income inclusion by U.S. shareholders of controlled foreign corporations (CFCs) that invest in U.S. property, should not apply to corporate shareholders.
the TCJA’s implementation of a hybrid territorial international tax regime mitigates the benefit of the election and may induce taxpayers to not make the election to avoid additional tax liability on the eventual sale of foreign target shares.
The new "repatriation tax" under the TCJA may cause individual partners and shareholders of flowthrough entities to obtain a deferred tax rate benefit by making this election.
The IRS issued proposed regulations implementing Sec. 951A’s global intangible low-taxed income provision, which requires a US shareholder of a controlled foreign corporation to include this income in the shareholder’s gross income.
One new opportunity created by the TCJA is the foreign-derived intangible income deduction in Sec. 250(a).
This item discusses provisions of the TCJA that seek to curb the erosion of the U.S. tax base.
This item discusses uncertainties regarding the
consequences of a midyear distribution
of PTI by a CFC.
Determining how to “properly attribute” a foreign
income tax to an income inclusion is unclear, particularly with respect to Sec. 956 inclusions.
In many instances, the new repatriation tax will produce harsh results for flowthrough taxpayers.
This article alerts the practitioner to when an information return may be necessary.
This column discusses the portions of the act likely to affect the typical inbound real estate investment structure.
Tax Court granted the government’s motion for summary judgment that intercompany transactions
between a U.S. parent's CFCs and its domestic subsidiaries resulted in the CFCs holding U.S. property.
This article provides an introduction to Sec. 956 inclusions.
This item discusses three options to achieve rollover equity when purchasing a Canadian company.
The regulations address the treatment of U.S. properties held by CFCs in certain transactions involving partnerships.
