Archives: CFC/Subpart F & Section 956

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Bloomberg BNA’s U.S. International Reporting & Compliance Seminar

On Tuesday, May 20th, I will be speaking at a seminar presented by Bloomberg BNA, entitled U.S. International Tax Reporting & Compliance. Held at the Marriot Biscayne Bay in Miami, the conference will also feature speakers from accounting firms Ernst & Young, KPMG and PwC. I will be speaking on “Computing the Gain from the … Continue Reading

The High-Tax Exception and Malta’s Refund System

A Match Made in Heaven U.S. shareholders of foreign corporations are generally not subject to U.S. federal income tax on the earnings of such corporations until those earnings are repatriated to the shareholders in the form of a dividend.  Where a foreign corporation is classified as a “controlled foreign corporation” (“CFC”), however, its “United States … Continue Reading
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