Controlled Foreign Corporation (CFC)

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 Andrew Mirisis 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 Andrew Mirisis 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 Andrew Mirisis 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 Andrew Mirisis 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 Andrew Mirisis 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 Stephanie Uribe 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), 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, Tax Reform

U.S. Shareholder: Changes Under the TCJA

By Jason B. Freeman Feb 21, 2019
Controlled Foreign Corporation (CFC), Cross-Border Tax Insights, International Tax

Advising International Business Ventures: Controlled Foreign Corporations and Subpart F

By Jason B. Freeman Dec 30, 2018
Controlled Foreign Corporation (CFC), International Tax, Participation Exemption, Tax Reform

Advising International Business Ventures: Tax Reform and a Quasi-Territorial Tax System

By Jason B. Freeman Dec 26, 2018