Controlled Foreign Corporations

Sales of CFCs Got Harder?

December 3, 2018 By Jasper L. (Jack) Cummings, Jr.

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.

State of Uncertainty: GILTI Considerations for Individuals

October 15, 2018 By Daniel Reach and Brian Harvel

Our International Tax Group explores the hidden terrain for individuals found in the new tax on global intangible low-taxed income (GILTI). The Section 250 deduction The renewed importance of Section 962 Beware of the C-corp. lobster pot Read the full advisory here. [...]Read more

Tax Act: Vote and Value

January 2, 2018 By Jasper L. (Jack) Cummings, Jr.

Our Federal Tax Group explains the nuances tax reform brings to the definition of a U.S. shareholder, including a surprise for controlled foreign corporations.

U.S. shareholders
The vote or value definition
Controlled foreign corporations

Click here to read the full advisory.