Corporate Taxes, Foreign Corporations, Passive Foreign Investment Company

Section 245A Overview and Requirements

Freeman Law on 10/21/2022

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

Purging the PFIC Taint

Freeman Law on 2/23/2022

A passive foreign investment company (PFIC) is a foreign corporation that meets either of two tests: an Asset test or an Income test. A U.S. person who is a direct or indirect shareholder of a corporation that satisfies...more

Share Buyback Transactions: U.S. Tax Consequences may differ for each U.S. Shareholder

Dorsey & Whitney LLP on 11/12/2021

On Thursday, November 4, 2021, the Office of the Superintendent of Financial Institutions announced that, subject to approval by the superintendent, Canadian banks and other financial institutions may begin repurchasing their...more

Impact of US Tax Reform on Insurance Companies

Skadden, Arps, Slate, Meagher & Flom LLP on 2/20/2018

On December 22, 2017, President Donald Trump signed into law a budget reconciliation act commonly referred to as the Tax Cuts and Jobs Act (TCJA). This sweeping tax bill represents the most comprehensive reform of U.S. tax...more

Reporting A Closely Held U.S. Corporation’s Overseas Activities

Farrell Fritz, P.C. on 2/14/2017

We have heard a lot about large, publicly-traded U.S. corporations that have parked trillions of dollars overseas to avoid the payment of U.S. income tax. We have heard how the tax system must be seriously broken to have so...more

Proposed Anti-Inversion Regulations Would Affect Foreign Insurers

Carlton Fields on 1/6/2015

For decades American companies have used so-called “corporate inversions” to lower their tax burdens on foreign-earned income. Typically, the American company is acquired by a foreign company located in a tax-favorable...more