Controlled Foreign Corporations

News & Analysis as of

Offshore Disclosure: What Needs To Be Disclosed? A Checklist

The following is a list of questions that should lead to the discovery of offshore assets, whether properly reported or not. If you answer yes to any of these questions, then you may have filing obligations and should seek...more

IRS PFIC Regs

The IRS issued definitions and reporting requirements for shareholders of passive foreign investment companies (PFICs) effective December 31, 2013 for US tax returns for 2013 and onwards. The regulations provide guidance for...more

Doing Business in Japan

I am pleased to present to you DLA Piper’s “Doing Business in Japan” Guide. Japan is the world’s third largest economy and remains cutting-edge in business. In 2012, 68 Global 500 Companies were headquartered in...more

Production Includes Growing

A U.S. shareholder of a controlled foreign corporation (CFC) has gross income on its share of the CFC's subpart F income. This income includes “foreign base company sales income” or FBCSI. ...more

Proposed Regulations On Imported Built-In Losses Include Some Controversial Aspects

Proposed Regulations (REG-161948-05, 9/6/13) dealing with the importation of built-in loss properties under Sections 334(b)(1)(B) and Section 362(e)(1) are designed "to prevent erosion of the corporate tax base through the...more

CFTC Grants Relief to CPOs Trading Through Subsidiaries

The Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) has granted no-action relief from certain reporting obligations to commodity pool operators (CPOs) of registered investment...more

CFTC No Action Letter for Controlled Foreign Corporations

On September 5, the CFTC issued a no-action letter to commodity pool operators of registered funds that trade in commodity interest through wholly-owned controlled foreign corporations (CFCs)....more

Orrick's Financial Industry Week in Review - September 9, 2013

Agency Template for Tailored Resolution Plans - On September 3, the FDIC and the Fed released an optional model template for tailored resolution plans required to be submitted by the Dodd-Frank Act. SEC Risk...more

Procurement CFC May Or May Not Generate Subpart F Income

A recent private letter ruling illustrates how a non-U.S. procurement corporation can generate Subpart F income, but also illustrates an exception to the creation of that income....more

NYSBA reports on inconsistencies in currency gain and loss Subpart F issues

The New York State Bar Association’s Tax Section has recently published a report highlighting that, in a variety of commonplace circumstances where a controlled foreign corporation (CFC) engages in certain routine treasury...more

No 15% Qualified Dividend Rate For CFC Inclusion

Back in 2011, we reviewed a Tax Court case that determined that income inclusion under the controlled foreign corporation (CFC) rules, while taxed like a dividend at ordinary income rates, could not qualify for the lower 15%...more

International Tax Impact of American Taxpayer Relief Act

On January 1, 2013, the Senate passed the American Taxpayer Relief Act, H.R. 8 (the "Bill"), by a vote of 89 to 8. Later that same day, the House of Representatives approved the Bill by a vote of 257 to 167. On January 2,...more

12 Results
|
View per page
Page: of 1