Why You Should Hire a Tax Professional to Review Your Foreign Legal Structure -
U.S. parented corporations that have foreign operations conducted through a foreign legal structure have significant U.S. tax filing and...more
1/25/2023
/ Business Entities ,
Corporate Structures ,
Corporate Taxes ,
FBAR ,
Foreign Corporations ,
Income Taxes ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
IRS ,
Parent Corporation ,
Tax Liability ,
Tax Planning ,
Tax Treaty
GRAs and Section 367(a)(1) Outbound Stock Transfer Rules Overview - Introduction to Section 367(a)(1), Outbound Stock Transfers, and Gain Recognition Agreements - Section 367(a) of the Internal Revenue Code (the “Code”)...more
Section 245A: Tax Efficient Repatriation of a Foreign Subsidiary’s Earnings -
Freeman Law frequently advises U.S. multinational corporations. United States-based international businesses are subject to complex reporting...more
10/21/2022
/ Controlled Foreign Corporations ,
Corporate Taxes ,
Foreign Corporations ,
GILTI tax ,
Income Taxes ,
Inflation Reduction Act (IRA) ,
IRS ,
Passive Foreign Investment Company ,
Subpart F ,
Tax Cuts and Jobs Act ,
Tax Reform