On July 20, 2020, the US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (REG-127732-19) (the 2020 Proposed Regulations) that would conform the historic Subpart F...more
8/7/2020
/ CFC ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Federal Trade Commission (FTC) ,
GAAP ,
GILTI tax ,
IFRS ,
Income Taxes ,
IRS ,
New Rules ,
Proposed Regulation ,
Shareholders ,
Subpart F ,
Tax Cuts and Jobs Act ,
Tax Rates ,
U.S. Treasury
Health Care Private Equity Investments in India -
A flurry of recent private equity (PE) investments in the Indian health care sector demonstrates strong investor appetite and opportunities.
India is one of the fastest...more
Under Subpart F, certain types of income and investments of earnings of a foreign corporation controlled by US shareholders (controlled foreign corporation, or CFC) are deemed distributed to the US shareholders and subject to...more