Entries tagged “subpart f income rules”
CPE Tax Webinar: Subpart F Income Rules and Sections 956, 958 and 1248: The Reporting Challenges of Controlled Foreign Corporations. Thursday, July 21, 2016
events July 21, 2016
Baseline Foreign source income earned by a foreign corporation is generally not taxed by the U.S. until the income is distributed — or made available on a “permanent basis” — to the U.S. shareholder(s) or invested in U.S. property. This deferral of U.S. taxation has been allowed from a policy standpoint on the grounds that it encourages investment…
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