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Foreign Corporations Controlled Foreign Corporations

Rivkin Radler LLP

The Supreme Court’s Non-Opinion On The “Realization” of Income – A Lost Opportunity?

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In less than four months, the citizens of the United States will be electing their next President to a four-year term. They will also be deciding which of the two major political parties will “control” the Senate, the House,...more

Freeman Law

Supreme Court Upholds Section 965 Mandatory Repatriation Tax

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On June 20, 2024, the U.S. Supreme Court issued its long-anticipated decision in Moore v. United States, in which a 7-2 majority upheld the constitutionality of the mandatory repatriation tax (“MRT”) under section 965 of the...more

Gray Reed

SCOTUS Upholds MFT: Moore Et Ux v. US

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On June 20, 2024, the Supreme Court released its opinion in Moore et ux v. US, authored by Kavanaugh, decided by 6-3 vote and marking a rare instance for the Court to interpret the 16th Amendment, upholding the...more

Burns & Levinson LLP

Client Advisory: Repatriation Tax on Shareholders | Moore v. U.S.

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The Tax Cuts and Jobs Act of 2017 amended the law to introduce a new, one-time, mandatory repatriation tax on trillions of dollars of accumulations held abroad by American-controlled foreign entities. The tax is imposed on...more

Freeman Law

El IRS actualiza reglas sobre los ajustes a la base gravable en las distribuciones a mitad de año por las CFC para evitar las...

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Durante años, había existido incertidumbre entre los profesionistas que se dedican a la materia fiscal sobre sobre si las ganancias obtenidas a mitad de año por una Corporación Extranjera Controlada (por sus siglas en inglés,...more

Eversheds Sutherland (US) LLP

Another CAMT crumble: IRS releases Notice 2024-10 addressing potential double counting from CFC dividends

On December 15, 2023, the Internal Revenue Service (IRS) and Department of the Treasury (Treasury) released Notice 2024-10 (Notice) addressing the potential double counting of income from controlled foreign corporations...more

Rivkin Radler LLP

Supreme Court to Decide: No Realization Means No Moore Income Tax?

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Many of you, perhaps most, may have read about a case that will be heard by the U.S. Supreme Court during its current term. The case, Moore v. United States, comes out of the Ninth Circuit Court of Appeals. The Supreme Court...more

Arnall Golden Gregory LLP

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

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

Rivkin Radler LLP

Enough Already – Eliminate Downward Attribution and Accidental CFCs

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It’s Complicated- The Code includes a number of complex rules that are aimed at those overseas business and investment activities of U.S. taxpayers that Congress has determined may result in the improper deferral or...more

Freeman Law

Section 245A Overview and Requirements

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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

Barnea Jaffa Lande & Co.

EU Proposes to Regulate Companies That Receive Foreign Governments Support – How Will This Affect Foreign and Israeli Companies?

On July 13, 2022, the European Parliament and the European Council agreed on a new regulation concerning “foreign subsidiaries that distort the European market.” Their agreement is the final stage prior to voting on the...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

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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

Freeman Law

Private Equity: Offshore Investments and Phantom Income

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Private Equity: Offshore Investments and Phantom Income - Private equity funds pool capital for investment in privately-held businesses. Increasingly, PE funds are looking to global investment markets and foreign...more

Eversheds Sutherland (US) LLP

Rev. Proc. 2021-26 provides accounting method change procedures for CFCs seeking to use the alternative depreciation system

Recently released Revenue Procedure 2021-26 (the Revenue Procedure) provides taxpayers with guidance regarding accounting method changes made on behalf of foreign corporations. The Revenue Procedure: ..Allows controlled...more

International Lawyers Network

Establishing A Business Entity In Argentina (Updated)

Types of business entities - The two most common types of legal entities adopted in Argentina are the limited liability company (“Sociedad de Responsabilidad Limitada” or “SRL”) and the corporation (“Sociedad Anónima” or...more

Alston & Bird

From Obscurity to Spotlight: The Section 962 Election

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Our International Tax Group addresses an election under Section 962 available to individual U.S. shareholders of certain foreign corporations to be taxed as a C corporation, which before tax reform was a rarely utilized and...more

Skadden, Arps, Slate, Meagher & Flom LLP

The Tax Cuts and Jobs Act’s Impact on Cross-Border Transactions

Two years after the enactment of the Tax Cuts and Jobs Act (TCJA), the most significant tax reform enacted in a generation, taxpayers continue to encounter substantial uncertainty arising from interpretations of new statutory...more

Fenwick & West LLP

PFIC: What U.S. Investment Funds Should be Particularly Aware of and Newly Proposed Regulations

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U.S.-based venture capital and other funds that invest in foreign companies must be careful to avoid the passive foreign investment company (PFIC) rules, which could substantially increase the tax owed on exit for U.S....more

Proskauer - Tax Talks

IRS provides very modest relief from downward attribution resulting from the repeal of section 958(b)(4)

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On October 2, 2019, the Internal Revenue Service (“IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued Revenue Produce 2019-40 (the “Revenue Procedure”) and proposed regulations (the “Proposed Regulations”)...more

Alston & Bird

Down the Rabbit Hole: Guidance Addressing Downward Attribution After Repeal of Section 958(b)(4)

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The IRS released Proposed Regulations and a Revenue Procedure addressing the Tax Cuts and Jobs Act’s repeal of Section 958(b)(4). Our International Tax Group explores how this guidance affects numerous provisions of the Code....more

McDermott Will & Emery

Weekly IRS Roundup September 30 – October 4, 2019

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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

A&O Shearman

Guidance on CFC ‘Downward Attribution Rules’ Provides Limited Relief to US Taxpayers

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On October 1, 2019, the Internal Revenue Service (IRS) issued Revenue Procedure 2019-40 (Revenue Procedure) and proposed regulations (Proposed Regulations) addressing issues related to the repeal of section 958(b)(4) by the...more

Wilson Sonsini Goodrich & Rosati

Corporate Tax 2019 - Seventh Edition - USA Chapter

Since December 22, 2017, corporate tax practitioners in the United States have been predominantly focused on the impact of legislation commonly known as the Tax Cuts and Jobs Act (the “Act”), which was signed into law on that...more

Foodman CPAs & Advisors

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

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

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