CFC

News & Analysis as of

Affirmative Use of U.S. Partnerships in Inbound Tax Planning

A “U.S. shareholder” of a controlled foreign corporation (CFC) is required to include in its gross income its pro rata share of a CFC’s “subpart F” income, regardless of whether such income is distributed. In general, a CFC...more

IRS Chief Counsel Shrugs Off Taxpayer’s Section 956 Gambit

In a recently released Chief Counsel Advice Memorandum (the “Memorandum”), the IRS Office of Chief Counsel (International) addressed an interesting and somewhat creative internal financing structure deployed by a taxpayer...more

Tax Planning for the Privatization of the Space Industry

The privatization of the space industry has seen dramatic growth in recent years, and it appears that more significant developments are on the horizon....more

Federal Circuit’s Metcalf Decision a Big Win for Contractors

In a recent decision, the U.S. Court of Appeals for the Federal Circuit (“CAFC”) the supervising court for the Court of Federal Claims and the Boards of Contract Appeals, among others) clarified important legal principles...more

Information Letter: Update on legislative developments in Russia. Governmental De-offshoring initiatives. Proposed new CFC and...

When it was first revealed by President Vladimir Putin a few years ago that the offshore-backed modus operandi for the Russian economy could no longer be tolerated, very few could have predicted that the Government would be...more

Updated PFIC And CFC Definitions And Reporting Rules

The IRS has issued updated reporting regulations under Code Sections 1291, 1298, 6038 and 6046. A lot of the changes are technical definitions, and relate to updates from proposed regulations going back to 1992. ...more

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