Subpart F

News & Analysis as of

Focus on Private Equity - July 2014

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

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

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

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

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

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

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

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

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