Archive: subpart f

  • Clear Filters

Section 338(g) Election for the Acquisition of a Foreign Target Corporation

A Section 338 election has the effect of recharacterizing a taxable stock acquisition as a deemed asset acquisition. The advantage to the buyer is the step up in the basis of the assets deemed acquired to the fair market value on the date of purchase. In the context of a cross-border acquisition, there are some […]
August 21, 2015

Offshore Voluntary Disclosure Program Still Open for Quiet Disclosures and Formal Disclosures

In January 2012, the IRS extended the Offshore Voluntary Disclosure Program. The program allows U.S. taxpayers to pay penalties and taxes for prior years in connection with the filing of delinquent U.S. international tax reporting forms. The forms that may be filed in a disclosure include the Form 5471 regarding ownership of a foreign corporation […]
July 22, 2013

The Basics to Know About Foreign Tax Credits

1. Foreign Taxes Paid by a U.S. Company Conducting Business Activities Directly in a Foreign Country or through a Foreign Branch C Corporation – A U.S. company that is a C corporation which conducts business in a foreign country directly or through a foreign branch may claim a foreign tax credit for foreign taxes paid […]
October 25, 2012

International Tax Series: Are You a U.S. Shareholder in a Controlled Foreign Corporation? The Basics to Know about Subpart F

A controlled foreign corporation (CFC) is a foreign corporation of which more than 50% of the vote or value of the stock is owned by U.S. shareholders who each own at least 10% of the voting stock.  CFCs are subject to Subpart F of the U.S. Internal Revenue Code which includes Sections 951 et seq.  […]
July 12, 2012