One of the most powerful tools in cross-border tax planning is the ability to make a “check-the-box” election. Pursuant to the entity classification regulations under Internal Revenue Code §7701 (the “check-the-box...more
Converting Subpart F Income into Qualified Dividends -
U.S. shareholders of foreign corporations are generally not subject to tax on the earnings of such corporations until the earnings are repatriated to the...more
Section 871(m) was enacted in 2010 to curb the perceived abuse of foreign persons using derivatives — primarily notional principal contracts (NPCs) or swaps — to replicate the ownership of an underlying U.S. equity without...more
Many South Florida-based companies conduct business operations throughout Latin America. Typically, these operations are conducted through wholly-owned foreign subsidiaries.
Originally Published in Law360 - October 29,...more
Pass-through structures -
Many South Florida-based companies conduct business operations throughout Latin America. Typically, these operations are conducted though wholly-owned foreign subsidiaries....more