"Describes the general rules for U.S. income taxation of United States shareholders of controlled foreign corporations (CFCs) under Subpart F. It begins with a discussion of the background and legislative history of Subpart F.A detailed analysis is provided of the ownership tests that must be satisfied for Subpart F to apply, including such key terms as "controlled foreign corporation," "United States person," and "United States shareholder." This portfolio also describes the categories of items included in U.S. shareholders' income under Subpart F, and the rules for determining the amounts includible in income and the U.S. tax treatment. It further provides an overview of the tax results to U.S. shareholders of various transactions involving CFCs, including the organization and reorganization of a CFC, CFC distributions, and liquidations and dispositions of CFCs. Finally, it describes the rules coordinating Subpart F with other special rules that apply to foreign entities and summarizes the return and compliance rules that apply to CFCs."
Published: Washington, D.C., 2000-2007.
Bibliography, etc. Note
Includes bibliographical references.
Formatted Contents Note
Detailed analysis. Introduction Background and legislative history Overview of subpart F and related provisions Definition of U.S. shareholder Definition of controlled foreign corporation Stock attribution rules Items subject to current inclusion under [section] 951(a) Determination of the amounts of [section] 951(a) items Earnings and profits limitations Pro rata share taxable to U.S. shareholders Exclusion for previously taxed income Adjustments to basis in CFC stock and other property Organizations, reorganizations and dispositions of CFCs Coordination of subpart F with passive foreign investment company provisions Returns and reporting requirements Working papers.
Digital File Characteristics
System Details Note
Mode of access: World Wide Web.
Source of Description
Title from title screen (viewed June 25, 2010).