PLR 202304008: Taxpayer Does Not Have Section 961(b)(2) Gain for Mid-Year Distributions -
Introduction to Section 961 and Mid-Year Distributions -
For years, there has been a longstanding question under the subpart F...more
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
10/21/2022
/ Controlled Foreign Corporations ,
Corporate Taxes ,
Foreign Corporations ,
GILTI tax ,
Income Taxes ,
Inflation Reduction Act (IRA) ,
IRS ,
Passive Foreign Investment Company ,
Subpart F ,
Tax Cuts and Jobs Act ,
Tax Reform