Subpart F

Subpart F

Special category of foreign-source "unearned" income that is currently taxed by the IRS whether or not it is remitted to the US

Subpart F

In U.S. taxation, income from foreign subsidiaries of American companies. Income under subpart F is subject to taxation even if it is not repatriated into the United States. Interestingly, subpart F income also includes the amount of money the subsidiary paid in bribes to foreign officials.
References in periodicals archive ?
959(c)(2) account, from current- or prior-year subpart F income inclusions and Sec.
These provisions, together with the treatment of the European Union as one country for Subpart F purposes, will effect meaningful reform.
the Commissioner that assembly operations performed by two foreign subsidiaries of Bausch & Lomb constituted "manufacturing" for purposes of the subpart F provisions, and income from the sale of the company's assembled goods was not considered subpart F income.
The Revenue Reconciliation Bill of 1995, if enacted, would clarify the treatment of Subpart F income earned by a controlled foreign corporation (CFC) in which a tax-exempt organization is a U.
taxpayer, as a shareholder of the CFC, may be required under subpart F (Secs.
Rather than imposing a complex subpart F analysis on the active income of all business operations, the original 1962 legislation provided a substantial de minimis rule that excluded from subpart F amounts equal to up to 30 percent of a CFC's gross income.
S persons, each of whom owns at least 10 percent directly or indirectly), or a Foreign Personal Holding Company (FPHCO), some or all of the deemed asset sale gain could be Subpart F or FPHCO income.
Commissioner, ruling that a controlled foreign corporation's (CFC) distributive share of income from a foreign partnership be treated as if it was directly earned by the CFC and, therefore, characterized as subpart F income.
Illinois Department of Revenue, the Illinois Appellate Court considered the characterization of Subpart F income for state law purposes.
shareholders of a CFC generally are required to currently include the CFC's subpart F earnings in income, regardless of whether an actual dividend has been distributed, under Sec.
Controlled foreign corporations (CFCs), as defined in section 957 of the Internal Revenue Code, that have Subpart F income.