Alston & Bird Tax Blog

CFC

Downward Stock Attribution for CFC Purposes

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Missing piece to CARES? Our Federal Tax Group excavates this missing piece and investigates how it would have restored what was repealed by the Tax Cuts and Jobs Act. Restoration of Section 958(b)(4) New Section 951B A newly minted controlled foreign corporation (CFC) regime Ready full advisory here. [...]Read more

From Obscurity to Spotlight: The Section 962 Election

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In case you missed it's release right before the President's Day holiday weekend, our International Tax Group addressed an election under Section 962 available to individual U.S. shareholders of certain foreign corporations to be taxed as a C corporation, which before tax reform was a rarely utilized and often forgotten tool that has recently been thrust into the spotlight due to its potential benefits. The rise in popularity of the Section 962 election Smith v. Commissioner, an unfavorable ruling for U.S. shareholders receiving distributions of foreign earnings subject to a Section 962 [...]Read more

Sales of CFCs Got Harder?

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Our Federal Tax Group gives a glimpse into the brave new world of selling foreign assets and stock in the wake of the Tax Cuts and Jobs Act.

  • Selling a U.S. sub versus selling a CFC
  • GILTI as a new option over Subpart F
  • Analyzing the options

Read the full advisory here.

Plot Twist – Proposed Regulations Mean Section 956 Did Not Actually Survive Tax Reform Intact

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Our International Tax Group takes stock of new proposed regulations that try to keep Section 956 relevant despite the Tax Cuts and Jobs Act. Many were left scratching their heads “A result directly at odds with the manifest purpose of Section 956” Impact of the proposed regulations Read the full advisory here. [...]Read more