Subpart F

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
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
GILTI, International Tax, Subpart F

Final Regulations on Stock Owned by Domestic Partnerships under Subpart F.

By TL Fahring Jan 29, 2022