Coming regulations will reduce tax benefits of inversions by preventing certain uses of
controlled foreign corporations and closing loopholes in the Sec.
The statistics presented below pertain only to FDEs with tax owners that are
controlled foreign corporations.
Department of the Treasury and the Internal Revenue Service relating to proposed regulations 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.
persons who are officers, directors, or shareholders of
controlled foreign corporations.
Extraterritorial Income and
Controlled Foreign Corporations.
shareholders of partners that are
controlled foreign corporations, attempt--through special partnership allocations--to claim foreign tax credits not matched by income subject to U.
More than 50 island companies (subsidiaries of major corporations) have switched to another tax code provision (Section 901), known as
Controlled Foreign Corporations (CFCs), but not all companies are able to find tax shelter under this provision.
The focus of Subpart F is on
controlled foreign corporations, which are defined as having more than 50 percent of their voting power or stock value owned by U.
This measure will permit corporations to access cash from their
controlled foreign corporations (CFCs) without having an income inclusion for U.
corporations (see Active versus inactive
Controlled Foreign Corporations in the Explanation of Selected Terms section of this article).
965 to repatriate earnings from their
controlled foreign corporations (CFCs) at n reduced rate (see Industry Directive #1 on Section 965
tax system provided by the check-the-box rules, noting that in some cases the proposed form would require taxpayers to submit more information in respect of disregarded entities than is currently required for
controlled foreign corporations.
