CFCs
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.
The IRS issued regulations aimed at preventing controlled foreign corporations from using partnerships to avoid Sec. 956, which requires income inclusion for certain investments in U.S. property.
The IRS issued regulations aimed at preventing controlled foreign corporations from using partnerships to avoid Sec. 956, which requires income inclusion for certain investments in U.S. property.
Treating a Sec. 956 inclusion as not a distribution for purposes of Regs. Sec. 1.952-1(f)(2)(iii) leads to unintended results under certain fact patterns.
A required person who fails to file the form or files a late or incomplete form is subject to substantial monetary penalties.
IRS inversion guidance introduces new restrictions on corporate inversions and post-inversion restructuring transactions.
Despite IRS moves to curb corporate inversions, some multinational corporations still search for low-tax jurisdictions.
This item provides an overview of E&P of foreign corporations and several common misconceptions that directly affect E&P.
The regulations limit the application of the “active rents and royalties” exception to foreign
personal holding company income, expanding the instances in which a controlled foreign corporation will be treated as holding U.S. property.
