Introduction: Consolidated Groups and Section 951(a)(2)(B) Tax Planning -
On December 9, 2022, Treasury and the IRS released proposed regulations that are intended to stop certain U.S. shareholder tax planning under...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