Controlled Foreign Corporation (CFC)

Controlled Foreign Corporation (CFC), Corporate, Repatriation, Subpart F

Supreme Court Upholds Section 965 Mandatory Repatriation Tax

By TL Fahring Jun 28, 2024
Controlled Foreign Corporation (CFC), Cross-Border Tax Insights, International Tax, PLR, Subpart F

El IRS actualiza reglas sobre los ajustes a la base gravable en las distribuciones a mitad de año por las CFC para evitar las ganancias de la Sección 961(b)(2).

By Freeman Law Jun 11, 2024
Controlled Foreign Corporation (CFC), Cross-Border Tax Insights, International Tax, PLR, Subpart F

IRS: Basis Adjustments Apply to CFC Mid-Year Distributions to Prevent Section 961(b)(2) Gain

By Freeman Law Mar 13, 2023
Controlled Foreign Corporation (CFC), Cross-Border Tax Insights, Form 5471, International Tax, IRS Disclosure, Offshore Tax, Outbound Transfer, Tax Planning

Reviewing a Foreign Legal Structure

By Freeman Law Jan 24, 2023
Alerts, Controlled Foreign Corporation (CFC), Economic Substance, GILTI, IRS Regulations, Subpart F

IRS Issues Proposed Regulations on Section 951(a)(2)(B) Planning.

By Freeman Law Dec 19, 2022
Controlled Foreign Corporation (CFC), Cross-Border Tax Insights, GILTI, International Tax, Participation Exemption, Repatriation, Subpart F, Tax Planning

Strategies to Recharacterize Gain with Untaxed Foreign Earnings.

By Freeman Law Nov 02, 2022
Controlled Foreign Corporation (CFC), Cross-Border Tax Insights, Subpart F

Whirlpool Petition for Cert

By Gregory Mitchell Oct 27, 2022
Controlled Foreign Corporation (CFC), Cross-Border Tax Insights, Subpart F

Withdrawal of 2006 Proposed PTEP Regulations

By Freeman Law Oct 21, 2022
Controlled Foreign Corporation (CFC), Cross-Border Tax Insights, Deductions, GILTI, International Tax, Participation Exemption, Structuring, Subpart F, Tax Planning

Section 245A Overview and Requirements

By Freeman Law Oct 06, 2022
Controlled Foreign Corporation (CFC), PLR

How are stock purchases treated for tax purposes under 26 USC 338? An IRS Letter Ruling on asset acquisitions.

By Freeman Law Aug 10, 2022
Controlled Foreign Corporation (CFC), Cross-Border Tax Insights, International Tax

Ninth Circuit Rejects Constitutional Challenges to Section 965 Tax

By TL Fahring Jul 05, 2022
Controlled Foreign Corporation (CFC), Cross-Border Tax Insights, International Tax

The Section 962 Election

By Jason B. Freeman Apr 18, 2022
Controlled Foreign Corporation (CFC), Corporate, Cross-Border Tax Insights, Foreign Tax Credit, International Tax, Tax Court, The-Tax-Court-in-Brief Insights

Tax Court in Brief | AptarGroup, Inc. v. Comm’r | Foreign Tax Credits and Interest Expense Allocation and Apportionment

By Freeman Law Mar 18, 2022
Controlled Foreign Corporation (CFC), Corporate, Cross-Border Tax Insights, International Tax, Private Equity

Private Equity: Offshore Investments and Phantom Income

By Jason B. Freeman Feb 14, 2022
Controlled Foreign Corporation (CFC), International Tax, Tax Court, The-Tax-Court-in-Brief Insights

Flume II: The Tax Court’s Recent Decision Involves UBS of Switzerland and Controlled Foreign Corporations

By Jason B. Freeman Jun 15, 2020
Controlled Foreign Corporation (CFC), Cross-Border Tax Insights, International Tax

IRS Form 5471 – Information Return of U.S. Persons With Respect to Certain Foreign Corporations

By Jason B. Freeman Jan 10, 2020
Controlled Foreign Corporation (CFC), Cross-Border Tax Insights, GILTI, International Tax, Tax Reform

Advising International Business Ventures: “Tested Income” under GILTI

By Jason B. Freeman Mar 07, 2019
Controlled Foreign Corporation (CFC), Corporate, Cross-Border Tax Insights, International Tax, Tax Reform

U.S. Shareholder: Changes Under the TCJA

By Jason B. Freeman Feb 21, 2019