 |
 |
       |
|
|
 Outgoing InvestmentDoes the U.S. tax the income of a foreign corporation that is owned by a U.S. person? The U.S. does not tax income earned by a foreign corporation that is owned by a U.S. person until the earnings are repatriated to United States shareholders. The Code provides various exceptions to this general deferral rule, however, such as the subpart F rules for controlled foreign corporations (CFCs). The Revenue Reconciliation Act of 1993 requires 10 percent United States shareholders of certain CFCs to include in their current income their pro rata shares of a specified portion of the CFC's current and accumulated earnings.
Firm |
Practice Areas |
Important Developments |
Client Resources |
Search |
Home The information you obtain at this site is not, nor is it intended to be, legal advice. You should consult an attorney for individual advice regarding your own situation. Copyright © by Gatti & Associates Attorneys at Law. All rights reserved. You may reproduce materials available at this site for your own personal use and for non-commercial distribution. All copies must include this copyright statement.
|
|
