GILTI

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, Deductions, GILTI, International Tax, Participation Exemption, Structuring, Subpart F, Tax Planning

Section 245A Overview and Requirements

By Freeman Law Oct 06, 2022
Cross-Border Tax Insights, GILTI, International Tax, Subpart F

Final Regulations on Stock Owned by Domestic Partnerships under Subpart F

By TL Fahring Jan 29, 2022
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), Cross-Border Tax Insights, GILTI, International Tax, Tax Reform

Advising International Business Ventures: Tax Reform’s New GILTI Tax

By Jason B. Freeman Jan 14, 2019