Controlled Foreign Corporations

Final FDII Regulations Released

July 16, 2020 By Edward Tanenbaum, Richard Slowinski and Stefanie Kavanagh

Talk about a summer beach read... The IRS’s final regulations for Section 250 deductions for FDII and GILTI are here for your light summer reading. Better yet, let our International Tax Group explain it all for you. The Section 250 deduction generally applies to domestic C corporationsA more relaxed and flexible approach to documentation and substantiation requirementsClarification for the software industry on foreign use of digital sales and advertising Read the full advisory here. [...]Read more

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.