Participation Exemption

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, 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), 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