Partial filing requirements exist for noncontrolled foreign corporations and for controlled foreign corporations
which are not controlled by a single U.S.
Tax Executives Institute appreciates this opportunity to present its views on the December 2008 regulations providing further guidance on 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.
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.S.
The history of controlled foreign corporations
in United States tax law is characterized by reduction of the tax deferral advantages of United States corporations operating businesses overseas through foreign corporations.
Confidential Transactions of Controlled Foreign Corporations
Substantially clarify the application and operation of the indirect participation rules, especially for reporting shareholders of controlled foreign corporations
As will be discussed in Part II of this article, under "foreign corporations," subpart F income is generally passive income or income earned by a controlled foreign corporation
(CFC) outside its country of incorporation from certain related-party transactions.
* Eliminate individual filings for each controlled foreign corporation
(CFC) and simply include a schedule of CFCs containing key information, including the balance in the E&P and tax pools.
parent that are part of a back-to-back loan arrangement with a controlled foreign corporation
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
Congress accorded Treasury authority to treat ICI derived by a foreign person (e.g., a controlled foreign corporation
) as domestic source as necessary to prevent manipulation.