Partial filing requirements exist for noncontrolled foreign corporations and for controlled foreign corporations
which are not controlled by a single U.
We believe that the diversity and professional training of our members enable us to bring a balanced and practical perspective to the 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).
residents, the insurer is not a controlled foreign corporation
, and the deferral of underwriting income is secure.
Two of the largest studies of international income and taxes conducted by Statistics of Income are the Corporate Foreign Tax Credit and Controlled Foreign Corporation
Thus, reporting shareholders of controlled foreign corporations
(CFCs) must seemingly disclose the CFC's participation in "listed transactions," transactions offered under conditions of confidentiality, transactions with contractual protection, transactions generating section 165 losses, and transactions involving brief asset holding periods.
The requirement for separate baskets for dividends from each 10/50 company was among the most complicated provisions of the 1986 Act, and in 1998, Congress acted to afford taxpayers an election to use a "look-through" rule for dividends (similar to the one provided for controlled foreign corporations
under IRC [sections] 904 (d)(3)).
Hopscotch loans involve repatriation of foreign earnings by having controlled foreign corporations
(CFCs) make loans to their new foreign parent instead of to the former U.
Extraterritorial Income and Controlled Foreign Corporations
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.
persons who are officers, directors, or shareholders of 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.
multinational companies to repatriate accumulated income earned abroad by providing an 85 percent deduction for certain dividends from controlled foreign corporations