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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Part Two of the TCJA Attribution Rules: The Expansion Upward

In our blog post titled “Owning” Shares that Aren’t Yours: The Code’s Confusing Definition of “Ownership”, we introduced how U.S. Shareholders may be treated as...

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Part One of The TCJA Attribution Rules: Family Matters

Our previous post, “Owning” Shares that aren’t Yours: The Code’s Confusing Definition of “Ownership”, we discussed the broad terminology behind what the U.S. considers “ownership”...

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“Owning” Shares that aren’t Yours: The Code’s Confusing Definition of “Ownership”

The Code employs various definitions of what constitutes “ownership” in various circumstances, and with regards to the classification of foreign companies as CFCs, the definition...

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The “Controlled Foreign Corporation” Regime: What is a CFC Anyway?

While the U.S. tax system appears to be federal in nature, the U.S. uses the Internal Revenue Code to cast a wide web and bring...

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Is a Nonresident Alien’s Sale of a Partnership Interest a U.S. Trade or Business?

Our previous post, The Code Fails to Define a “U.S. Trade or Business,” even though You’re Still on the Hook for Paying Taxes on It,...

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The Code fails to define a “U.S. Trade or Business,” even though You’re on the Hook for Paying Taxes on it

As mentioned in our prior post, Surprise! Even Nonresident Aliens may be Taxable in their U.S.-Sourced Income, a nonresident alien will be liable for U.S....

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Surprise! Even Nonresident Aliens may be Taxable on their U.S.-Sourced Income

Under the Tax Cuts and Jobs Act of 2017, a nonresident alien of the United States will be subject to U.S. taxation if they have...

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