IRS: Basis Adjustments Apply to CFC Mid-Year Distributions to Prevent Section 961(b)(2) Gain
By Freeman Law
Mar 13, 2023
Reviewing a Foreign Legal Structure
By Freeman Law
Jan 24, 2023
IRS Issues Proposed Regulations on Section 951(a)(2)(B) Planning.
By Freeman Law
Dec 19, 2022
Strategies to Recharacterize Gain with Untaxed Foreign Earnings.
By Freeman Law
Nov 02, 2022
Whirlpool Petition for Cert
By Gregory Mitchell
Oct 27, 2022
Withdrawal of 2006 Proposed PTEP Regulations
By Freeman Law
Oct 21, 2022
Section 245A Overview and Requirements
By Freeman Law
Oct 06, 2022
How are stock purchases treated for tax purposes under 26 USC 338? An IRS Letter Ruling on asset acquisitions.
By Stephanie Uribe
Aug 10, 2022
Ninth Circuit Rejects Constitutional Challenges to Section 965 Tax
By TL Fahring
Jul 05, 2022
Flume II: The Tax Court’s Recent Decision Involves UBS of Switzerland and Controlled Foreign Corporations
By Jason B. Freeman
Jun 15, 2020
IRS Form 5471 – Information Return of U.S. Persons With Respect to Certain Foreign Corporations
By Jason B. Freeman
Jan 10, 2020
Advising International Business Ventures: “Tested Income” under GILTI
By Jason B. Freeman
Mar 07, 2019
U.S. Shareholder: Changes Under the TCJA
By Jason B. Freeman
Feb 21, 2019
Advising International Business Ventures: Tax Reform’s New GILTI Tax
By Jason B. Freeman
Jan 14, 2019
Advising International Business Ventures: Controlled Foreign Corporations and Subpart F
By Jason B. Freeman
Dec 30, 2018
Advising International Business Ventures: Tax Reform and a Quasi-Territorial Tax System
By Jason B. Freeman
Dec 26, 2018