The FDE data in this article pertain only to active FDEs that are owned by controlled foreign corporations
Department of Treasury and the Internal Revenue Service issued final, temporary and proposed regulations to provide guidance regarding the treatment of foreign base company sales income from property produced under contract manufacturing arrangements and sold by controlled foreign corporations
under section 954(d) of the Internal Revenue Code (hereinafter the "December 2008 regulations").
shareholder" and the lower 25 percent threshold of controlled foreign corporation
The Tax Reform Act of 1986 again refined the controlled foreign corporation
concept in part to address the issue of U.
Substantially clarify the application and operation of the indirect participation rules, especially for reporting shareholders of controlled foreign corporations
A Court of Appeal affirmed (35) that, in calculating the includible portion of controlled foreign corporation
subpart F foreign-source income in its water's-edge report, the taxpayer could statutorily exclude dividends paid by certain second-tier subsidiaries to certain first-tier subsidiaries, because they were paid out of unitary income.
The term United States Shareholder means any shareholder described in section 951(b) without regard to whether the foreign corporation is a controlled foreign corporation
parent that are part of a back-to-back loan arrangement with a controlled foreign corporation
shareholders of a controlled foreign corporation
(CFC) are required to include in current income certain income of the CFC (referred to as "Subpart F" income).
Under paragraphs (e), (f), (g) and (h) of this section, transactions in certain property give rise to gain or loss included in the computation of foreign personal holding company income if the controlled foreign corporation
holds that property for a particular use or purpose.
And in 1997, Congress rectified an inequity that has existed for the past decade when it eliminated the overlap between the controlled foreign corporation
and passive foreign investment company rules.
Coming regulations will reduce tax benefits of inversions by preventing certain uses of controlled foreign corporations
and closing loopholes in the Sec.