CFCs--general overview

Resource Information

The work CFCs--general overview represents a distinct intellectual or artistic creation found in Biddle Law Library - University of Pennsylvania Law School. This resource is a combination of several types including: Work, Language Material, Continuing Resources.

Label

CFCs--general overview

Statement of responsibility

Lowell D. Yoder, Damon M. Lyon, David G. Noren

Title variation

Controlled foreign corporations general overview

Creator

• Yoder, Lowell D., 1955-

Contributor

• Lyon, Damon M
• Noren, David
• Tax Management Inc

Subject

• Corporations, Foreign -- Taxation -- United States
• Electronic books
• Income tax -- United States -- Foreign income
• Investments, Foreign -- Taxation -- United States
• Controlled foreign corporations -- Taxation -- United States

Genre

• Electronic books

Language

eng

Summary

"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."

Member of

• Tax management portfolios, 926-3rd

Cataloging source

BNA

Characteristic

updating web site

Entry convention

integrated entry

Former title

Subpart F--general

LC call number

KF6289.A1

LC item number

T35 no. 926-3rd (INTERNET)

Nature of contents

• dictionaries
• bibliography

Regularity

complete irregular

Series statement

Foreign income portfolios

Series volume

926-3rd