CFCs-- sections 959-965 and 1248 / William R. Skinner, Esq. ; a revision of a previous edition by Lowell D. Yoder, Esq. and Larry R. Kemm, Esq.
2006
INTERNET
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Details
Title
CFCs-- sections 959-965 and 1248 / William R. Skinner, Esq. ; a revision of a previous edition by Lowell D. Yoder, Esq. and Larry R. Kemm, Esq.
Former Title
Subpart F--sections 959-964, 1248 and related provisions
Added Author
Added Corporate Author
Imprint
Arlington, VA : Tax Management, Inc., [©2006]-
Description
1 online resource.
Frequency
Updated irregularly
Series
Tax management portfolios ; 6280.
Formatted Contents Note
Detailed analysis. I. Introduction
II. Exclusion from gross income of previously taxed earnings and profits
III. Section 960 deemed paid foreign tax credits
IV. Adjustments to basis of CFC stock and other property
V. Election by individuals to be subject to tax at Corporate rates
VI. CFC earnings and profits
VII. Gain from sale or exchange of CFC stock
VIII. Transition tax under [section] 965
IX. Participation exemption system
Table of worksheets.
II. Exclusion from gross income of previously taxed earnings and profits
III. Section 960 deemed paid foreign tax credits
IV. Adjustments to basis of CFC stock and other property
V. Election by individuals to be subject to tax at Corporate rates
VI. CFC earnings and profits
VII. Gain from sale or exchange of CFC stock
VIII. Transition tax under [section] 965
IX. Participation exemption system
Table of worksheets.
Summary
" ... describes the various rules that apply to the repatriation of the earnings and profits of a controlled foreign corporation (CFC) under subpart F of the Internal Revenue Code. Subpart F, including the global intangible low-taxed income (GILTI) rules of [section] 951A, is designed to tax the U.S. shareholder of a CFC on the shareholder's pro rata share of the corporation's subpart F income and GILTI, even when that income remains in corporate solution. In order to avoid double taxation of subpart F income or GILTI when it is repatriated to the shareholder, subpart F contains a number of provisions dealing with previously taxed earnings and profits, adjustments to the basis of CFC stock, the foreign tax credit, and disposition of stock in a CFC. This Portfolio provides a detailed discussion of those provisions."
Note
"This Portfolio revises and supersedes 930-2nd T.M., CFCs -- Sections 959-965 and 1248."
Revision of an earlier version by Laraine S. Rothenberg and Lowell D. Yoder. 1st ed. 1999-2005.
Formerly published in Washington, D.C., 2006-2007.
Revision of an earlier version by Laraine S. Rothenberg and Lowell D. Yoder. 1st ed. 1999-2005.
Formerly published in Washington, D.C., 2006-2007.
Bibliography, etc. Note
Includes bibliographical references.
System Details Note
Mode of access: World Wide Web.
Source of Description
Description baed on contents viewed February 23, 2023; title from title screen.
Location
www
Available in Other Form
Print version: Yoder, Lowell D., 1955- CFCs--sections 959-965 and 1248. [Washington, D.C.] : Tax Management Inc., ©2006-
Linked Resources
Alternate Title
BNA Premier package.
Call Number
INTERNET
Language
English
Copyright Information
Bloomberg Industry Group, Inc. 2022-
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