Hierarchy of the CFC and PFIC Code Sections

If you look back to our definition of a PFIC, it appears as though a foreign company can concurrently be a CFC and a PFIC....

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Should You File a Form 5471 or Form 5472?

If your business is expanding into the U.S. then you will need to determine exactly which forms to file and how much income to report...

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FBCI Exclusion One: The De Minimus Rule

In our earlier blog post, Digging Deeper into Subpart F Income: Foreign Base Company Income, we discussed how FBCI must be included as Supbart F...

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Double Tax on U.S sourced Capital Gains

The ATO have successfully argued in the Federal Court of Australia in the case of Burton v Commissioner of Taxation [2019] FCAFC 141 that only...

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Digging Deeper into Subpart F Income: Foreign Base Company Income

In our previous blog, Subpart F Income: The Briefer, we introduced Subpart F Income and how U.S. Shareholders of controlled foreign corporations must pay U.S....

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Subpart F Income: The Briefer

As mentioned in the previous blog, So You Own a CFC, What Now?, we introduced the fact that controlled foreign corporations must pay U.S. tax...

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What does ‘two-up’ have in common with selling Australian real estate while living in the US?

I am often asked how can a capital gain associated with your main residence that is tax-free in Australia be taxable in the U.S.? For...

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So You own a CFC, What Now?

In our whitepaper, The Expansion of “United States” Taxpayers: How the TCJA Drags Unassuming Foreign Companies and Individuals under its Scope, we analyze how recent...

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Stage Five Clinger: How the TCJA Latches onto Unassuming Foreign Personsthrough Constructive Ownership

In our whitepaper, The Expansion of “United States” Taxpayers: How the TCJA Drags Unassuming Foreign Companies and Individuals under its Scope, we discuss the how...

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Part Three of the TCJA Attribution Rules: Down the Rabbit Hole

In our blog post titled “Owning” Shares that aren’t Yours: The Code’s Confusing Definition of “Ownership”, we introduced how U.S. Shareholders of a foreign company...

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