News & Analysis as of

Subpart F C-Corporation

Farrell Fritz, P.C.

The Federal Anti-Deferral Rules For Foreign Income –Just A Reminder, There’s No Easy Way Out

Farrell Fritz, P.C. on

It’s Complicated- Coming to grips with the U.S. tax treatment of the foreign-sourced income of a closely held domestic business, and of commercial transactions involving such a business and its related foreign entities,...more

Farrell Fritz, P.C.

S Corps, CFCs & The Tax Cuts & Jobs Act

Farrell Fritz, P.C. on

Pro “C” Corporation Bias? Although closely-held businesses have generally welcomed the TCJA’s amendments to the Code relating to the taxation of business income, many are also frustrated by the complexity of some of these...more

McDermott Will & Emery

GILTI Rules Particularly Onerous for Non-C Corporation CFC Shareholders

McDermott Will & Emery on

The recently enacted tax reform legislation significantly expanded the application of Subpart F, including by adding a new inclusion rule for non-routine CFC income, termed “global intangible low-taxed income” (GILTI). The...more

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