Uncategorized

Hierarchy of the CFC and PFIC Code Sections

Posted in Uncategorized | Posted on Oct 16, 2019

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

Should You File a Form 5471 or Form 5472?

Posted in Tax Questions, Uncategorized | Posted on Oct 11, 2019

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

FBCI Exclusion One: The De Minimus Rule

Posted in Tax Questions, Uncategorized | Posted on Oct 11, 2019

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

Subpart F Income: The Briefer

Posted in Tax Questions, Uncategorized | Posted on Oct 3, 2019

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

So You Own a CFC, What Now?

Posted in Uncategorized | Posted on Sep 13, 2019

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

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