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Year-End Planning CFC

Bilzin Sumberg

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

Bilzin Sumberg on

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

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