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International Tax Law FAQ

March 25, 2014
What are the Two Main Categories of Subpart F Income?

What are the Two Main Categories of Subpart F Income?

There are two major categories of Subpart F income. First, there is insurance income, which is income that is earned by a CFC from the sale […]
March 25, 2014
US Shareholders Taxed on Distributive Share of CFC Income

US Shareholders Taxed on Distributive Share of CFC Income

Those persons who qualify as “U.S. shareholders” of a CFC are taxed on their distributive share of the income of the CFC that is deemed “Subpart […]
March 25, 2014
Constructive Ownership Rules for Foreign Corporation

Constructive Ownership Rules for Foreign Corporation

The rules for CFC are subject to various constructive ownership rules. The attribution and constructive ownership rules are used to discern whether a foreign corporation is […]
March 25, 2014

What is a Controlled Foreign Corporation (CFC)?

This is an important question. A corporation is a controlled foreign corporation if more than 50% of its shares are owned by U.S. shareholders. However, the […]
March 25, 2014
Can Government Tax Shareholders of a Foreign Corporation?

Can Government Tax Shareholders of a Foreign Corporation?

Unlike the general rule barring the U.S. government from taxing foreign corporations, the U.S. does have power to tax U.S. shareholders of foreign corporations. The U.S. […]
March 25, 2014
Are U.S. Corporations Taxed on Foreign Sourced Income?

Are U.S. Corporations Taxed on Foreign Sourced Income?

Yes. Corporations that are U.S. incorporated are also subject to worldwide U.S. taxation, even if the income is earned elsewhere (abroad). However, generally, the U.S. does […]