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... Read more
The U.S. Tax Terms You Need to Know
By way of introduction, the following blogs series is on the various tax topics found in our article, The Expansion of “United States”... Read more
Introduction on the United States Federal Income System
In our whitepaper, The Expansion of “United States” Taxpayers: How the TCJA Drags Unassuming Foreign Companies and Individuals under its Scope, we discuss... Read more
I don’t live in the US – why am I subject to US tax?
Author: Peter Harper How can the US tax me - doesn't the tax treaty stop me from being subjected to Double Tax? In... Read more
When will an Australian Trust be a Grantor Trust Under the Internal Revenue Code of 1986 (Code)?
Author: Peter Harper In many countries outside of the U.S. discretionary forms of trusts are used as both business planning and estate planning... Read more
