News & Analysis as of

Subpart F

IRS Targets Globally-Mobile Individuals and Businesses: The Importance of Proactive Planning

IRS targets globally-mobile individuals and businesses through its Global High Wealth Industry Group and its Large Business and International Division. Targeted taxpayers find these audits distracting, taking time from...more

Creating Non-Taxed “Previously Taxed Income”: The Ultimate Pre-Immigration Strategy

by Bilzin Sumberg on

According to recent statistics, immigrants and their U.S.-born children now number approximately 84.3 million people, or 27% of the overall U.S. population. The countries from which the largest numbers of these individuals...more

Tightening the Tax Screws on International IP Structures

by Carlton Fields on

For many years prudent international tax planning for multinational enterprises has included structures designed to minimize global taxes by developing or holding intangible property (IP) in foreign subsidiaries located in...more

A Comparison of Trump and House GOP Tax Reform Proposals

by Holland & Knight LLP on

With Republicans in control of the U.S. Senate, the U.S. House of Representatives and the White House starting in 2017, the federal government is now better positioned to move forward on comprehensive tax reform, with...more

IRS Addresses RIC Qualification Matters Related to Derivatives and Use of Blocker Corporations

by Goodwin on

On Wednesday, September 28, the IRS and Treasury Department proposed regulations under Section 851 of the Code that, if finalized, could prospectively invalidate dozens of private letter rulings treating subpart F and passive...more

Financial Services Weekly News - September 2016 #3

by Goodwin on

Editor's Note - Investment Company Institute Publishes FAQ on SEC No-Action Letter Regarding Auditor Independence. On September 23, the Investment Company Institute (ICI) published a memorandum (ICI Memo) responding to...more

U.S. Tax Implications of Offshore Migration of Intellectual Property

by Dorsey & Whitney LLP on

Challenges of Transferring IP Offshore - What constitutes intellectual property (“IP”) has long been a contested issue in tax practice, but generally includes intangible assets as wide-ranging as patents, copyrights,...more

New Temporary Regulations Narrow the Application of the Subpart F Active Rents and Royalties Exception

by McDermott Will & Emery on

On September 2, 2015, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued Temporary Regulation § 1.954-2T concluding that third party arrangements cannot be taken into account for...more

Use of Estonia in U.S. International Tax Planning

by Bilzin Sumberg on

According to recent estimates, Estonia, which is situated halfway between Stockholm and St. Petersburg, currently has more than 350 start-up technology companies – one for every 3,700 citizens – and the government expects...more

International Tax Grows Up: The Tax Section at 75, Subpart F at 53, and the Foreign Tax Credit at 97

by Pepper Hamilton LLP on

As the Tax Section celebrates its 75th anniversary, I was asked to reflect on the Section’s contribution in the international tax arena and on how the Section’s international community has grown. I started by recognizing the...more

Tax Alert: AM 2015-01—Does Previously Taxed Income “Tier up” to a Domestic Corporate Shareholder?

by Fenwick & West LLP on

In a recent chief counsel memorandum (AM 2015-01), the IRS addressed a long uncertain tax question: when a US corporate shareholder includes an amount in income under subpart F, does the subpart F inclusion increase the...more

Focus on Tax Strategies & Developments - November 2014

by McDermott Will & Emery on

REIT Spin-Offs: Recent Transactions and IRS Rulings - Several recent corporate spin-offs in the United States have involved real estate investment trusts (REITs). Provided several requirements are satisfied, including...more

Focus on Private Equity - July 2014

by McDermott Will & Emery on

In This Issue: - Latin American Private Equity on the Rise - Tax Considerations When Acquiring Non-U.S. Portfolio Companies—Mitigating Subpart F Inclusions - Private Equity Funds at Higher Risk of...more

Retroactive Tax Planning

by Bilzin Sumberg on

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

IRS Chief Counsel Shrugs Off Taxpayer’s Section 956 Gambit

by Mintz Levin on

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

The High-Tax Exception And Malta’s Refund System

by Bilzin Sumberg on

A Match Made in Heaven - U.S. shareholders of foreign corporations are generally not subject to U.S. federal income tax on the earnings of such corporations until those earnings are repatriated to the shareholders in...more

Proposals May Signal Direction of Future Tax Reform

After several years of hearings and forums intended to develop broad-based support for comprehensive tax reform, on February 26, 2014, House Ways and Means Committee Chairman David Camp (R-Mich.) released a draft tax reform...more

State + Local Tax Insights -- Spring 2014

by Morrison & Foerster LLP on

In This Issue: - Where’s Walden? Finding Protection under the Due Process Clause - Upcoming Speaking Engagements - CFCs and Subpart F Income in a California Water’s-Edge Election and What’s Wrong with the Apple...more

IRS Clarifies Manufacturing Exception, addresses Contract Manufacturers

by Williams Mullen on

In a recent private letter ruling, PLR 201340010, the Internal Revenue Service (the “IRS”) provides us with insights into meeting the “manufacturing exception” for foreign base company sales income (“FBCSI”) under § 954(d) of...more

Production Includes Growing

by Charles (Chuck) Rubin on

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

Procurement CFC May Or May Not Generate Subpart F Income

by Charles (Chuck) Rubin on

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

by DLA Piper on

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

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