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Income Taxes › Tax Planning › Controlled Foreign Corporations

Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect... more +
Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -
McDermott Will & Emery

[Event] Tax Symposium 2024 - May 14th - 15th, Chicago, IL

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Discover the latest global developments and planning opportunities to stay ahead of the curve at McDermott’s Tax Symposium 2024. Join us in Chicago for a full day of programming designed to equip corporate tax leaders with...more

Arnall Golden Gregory LLP

AGG Talks: Cross-Border Business - U.S. Tax Considerations for Scaling Across Borders

Arnall Golden Gregory LLP on

In this episode, Mike Burke, AGG Corporate partner and leader of the Ireland & Northern Ireland practice, explores U.S. tax considerations for foreign businesses scaling to the U.S., including issues such as the branch...more

Cadwalader, Wickersham & Taft LLP

Proposed Treasury Regulations Would Disallow Technique to Reduce Subpart F and GILTI Inclusions

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On December 9, 2022, Treasury released proposed regulations that would prevent consolidated groups from engaging in certain related party transactions to reduce the group’s Subpart F and GILTI inclusions. Specifically,...more

Freeman Law

The Section 962 Election

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For years, section 962 was a relatively obscure tax-planning mechanism. The Tax Cuts & Jobs Act, however, changed that, pushing the so-called section 962 election into vogue. Section 962 allows an individual shareholder of a...more

Freeman Law

Income Sourcing Rules – Foreign-Source and U.S.-Source Income

Freeman Law on

In the international tax context, the source of a taxpayer’s income can have significant implications. The source of income may determine whether a taxpayer qualifies for a foreign tax credit with respect to the income. Or,...more

Cadwalader, Wickersham & Taft LLP

Proposed Regs Affect PFIC Elections

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On January 25, 2022, the IRS and Treasury proposed regulations that would treat U.S. partners, instead of their partnerships, as PFIC shareholders for making qualified electing fund, mark-to-market, or purging elections,...more

Cadwalader, Wickersham & Taft LLP

Build Back Better Act: Comparison of Senate Finance Committee and House Tax Provisions

Cadwalader, Wickersham & Taft LLP on

Here's a summary of the new tax provisions in the Build Back Better Act proposed by the Senate Finance Committee, as compared to the version that the House passed on November 19, 2021....more

Cadwalader, Wickersham & Taft LLP

A Comparison of Recent Tax Proposals

Cadwalader, Wickersham & Taft LLP on

This chart compares the Biden Administration’s Fiscal Year 2022 Revenue Proposals (the Greenbook), to the tax proposals in the Build Back Better Act (BBBA) approved by the House Ways and Means Committee on September 15, 2021....more

Freeman Law

[Webinar] Freeman Law International Tax Symposium – General Attendee - November 18th - 19th, 8:00 am - 5:00 pm CST

Freeman Law on

Join leading tax experts from across the globe, as we discuss tax trends that are reshaping international taxation - An Experience Unlike Any Other - Find yourself on the cutting-edge of international tax law, with...more

Bilzin Sumberg

The Draft of the International Tax Overhaul: Where is Captain America?

Bilzin Sumberg on

On August 25, 2021, Senate Finance Committee Chair Ron Wyden, D-Ore., and fellow Senate Finance Committee Democrats Sherrod Brown of Ohio and Mark R. Warner of Virginia released draft legislation, and a related summary,...more

Morgan Lewis

Rules on Controlled Foreign Corporations in Kazakhstan May Change

Morgan Lewis on

The Kazakhstan Tax Code may change so that controlled foreign corporation rules will not apply to foreign persons that are residents of countries having a double tax treaty with Kazakhstan. Kazakhstan residents (both...more

Vinson & Elkins LLP

[Webinar] All in the Family: Applying the Business Interest Expense Limitation Within Groups - September 30th, 12:00 pm - 1:00 pm...

Vinson & Elkins LLP on

The 2017 Tax Cuts and Jobs Act generally limits the amount of business interest expense that a taxpayer may deduct. This webinar will cover newly issued final and proposed Treasury regulations under section 163(j), with a...more

McDermott Will & Emery

[Webinar] Virtual Tax Forum | GILTI and Subpart F High Tax Exception Regulations: Practical Aspects and Implications (New Guidance...

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The final and proposed regulations under sections 951A and 954 of the US Internal Revenue Code contain certain rules that may present planning opportunities—or possibly onerous results—depending on a taxpayer’s specific fact...more

Cooley LLP

Blog: Primer - U.S. Tax Considerations for Venture Capital Funds

Cooley LLP on

We are frequently asked by our fund manager clients about what tax issues they should consider when forming a new venture capital fund or investing in portfolio companies. In this post, we outline a few key considerations for...more

Fenwick & West LLP

Treasury and IRS Release Final and Proposed Foreign Tax Credit Regulations

Fenwick & West LLP on

On December 2, 2019, Treasury and the IRS released final and proposed regulations on the foreign tax credit. As expected, the final regulations finalize the 2018 proposed regulations relating mainly to the Tax Cuts and Jobs...more

McDermott Will & Emery

Weekly IRS Roundup December 16 – 20, 2019

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 16 – 20, 2019. December 16, 2019: The IRS released a notice extending the phase-in...more

McDermott Will & Emery

Weekly IRS Roundup November 18 – 22, 2019

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 18 – 22, 2019. November 19, 2019: The IRS published final regulations that affect United...more

McDermott Will & Emery

Weekly IRS Roundup September 30 – October 4, 2019

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 30 – October 4, 2019. September 30, 2019: The IRS published a draft of the tax year...more

Skadden, Arps, Slate, Meagher & Flom LLP

New IRS Rules on Timing of Income Recognition Raise Questions

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On September 5, 2019, the Treasury Department (Treasury) and the IRS released proposed regulations (Regulations) that would impact when accrual method taxpayers report amounts in gross income. Generally, Section 451 provides...more

Foodman CPAs & Advisors

IRS Initiates a Compliance Campaign for U.S. Persons with respect to Certain Foreign Corporations

Foodman CPAs & Advisors on

IRS Form 5471 is used by certain U.S. persons who are officers, directors, or shareholders in certain foreign corporations and must be attached to a covered Taxpayer’s Tax Return.  On April 16, 2019, IRS announced the...more

McDermott Will & Emery

Weekly IRS Roundup August 19 – 23, 2019

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 19 – 23, 2019. August 20, 2019: The IRS released a proposed regulation that provides...more

Bilzin Sumberg

Looking for a GILTI-Free Structure? Try Estonia

Bilzin Sumberg on

Estonia, the small Baltic country of just 1.3 million people situated halfway between Sweden and Russia, was named “the most advanced digital society in the world” by Wired magazine. According to recent figures, Estonian...more

Farrell Fritz, P.C.

U.S. Individuals Electing To Be Treated As Corporations: American Werewolves?

Farrell Fritz, P.C. on

The Tax Cuts and Jobs Act has been called a lot of things by a lot of different people. Certain provisions of the Act, however,coupled with recently proposed regulations thereunder, may result in its being known as the...more

Holland & Knight LLP

Relief on the Way to U.S. Individuals Owning Stock in a "Controlled Foreign Corporation" - Treasury Department's Proposed...

Holland & Knight LLP on

• The U.S. Department of the Treasury has released proposed regulations dealing with the application of the recent U.S. tax reform to U.S. shareholders of a "controlled foreign corporation" (CFC). • A foreign corporation...more

Foodman CPAs & Advisors

Understanding How to Compute a U.S. shareholder’s GILTI inclusion

Foodman CPAs & Advisors on

The Tax Cuts and Jobs Act added section 951A to the Internal Revenue Code. This new section requires a U.S. shareholder of a Controlled Foreign Corporation (CFC) to include in gross income the shareholder’s Global Intangible...more

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