Searching Content indexed under Shareholders by Ruchelman PLLC ordered by Published Date Descending.
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United States
10 Jul 2019
Peeling The Onion To Allocate Subpart F Income – This Will Make You Cry!
There has been a wealth of conversation addressing the amendment to the definition of a "U.S. Shareholder" in the context of a controlled foreign corporation introduced by the 2017 Tax Cuts and Jobs Act.
United States
18 Jun 2019
Holding Companies Of Europe – Tax Planning For European Expansion In A Changing Landscape
Prior to 2018, widely-used tax plans of U.S.-based multinational groups were designed to achieve three basic goals in connection with European operations: (i) the reduction of European taxes ...
United States
15 Jan 2019
C-Corps Exempt From Full Scope Of Foreign Income Inclusion
On October 31, 2018, the I.R.S. proposed regulations affecting controlled foreign corporations ("C.F.C.'s") and U.S. corporations that are considered to be U.S. Shareholders ...
United States
12 Dec 2018
A Deep Dive Into G.I.L.T.I. Guidance
The 2017 Tax Cuts and Jobs Act ("T.C.J.A.") introduced a new anti-abuse tax regime applicable to controlled foreign corporations ("C.F.C.'s").
United States
12 Dec 2018
Transition Tax – Proposed Regulations Are Here
The Treasury Department and the I.R.S. recently published proposed regulations on Code §965 (the "Proposed Regulations").
United States
12 Nov 2018
I.R.S. Proposed Regulations Provide Clarity On Code §965 Transition Tax
On August 1, 2018, the I.R.S. issued 145 pages of proposed regulations (REG-104226-18) relating to the Code §965 Transition Tax applicable to the 2017 taxable year of U.S. Shareholders...
United States
3 Aug 2018
Changes To C.F.C. Rules – More C.F.C.'s, More U.S. Shareholders, More Attribution, More Compliance
One of the principal revisions to U.S. tax law made by the Tax Cuts and Jobs Act ("T.C.J.A.") was a series of changes to the definition of the term Controlled Foreign Corporation ("C.F.C.").
United States
12 Apr 2018
A New Opportunity For Nonresident Aliens – Ownership In An S-Corp
Changes to U.S. tax law brought about by the 2017 Tax Cuts and Job Act ("T.C.J.A.") have affected many longstanding tax planning tools.
United States
13 Mar 2018
A New Tax Regime For C.F.C.'s: Who Is G.I.L.T.I.?
The 2017 Tax Cuts and Jobs Act introduces a new tax regime applicable to con¬trolled foreign corporations ("C.F.C.'s").
United States
2 Feb 2018
When Does An Aged Account Receivable Give Rise To A Deemed Repatriation?
Arrangements to shift formal voting power away from U.S. shareholders are not giv¬en effect if voting power is retained in reality.
United States
20 Nov 2017
Taxation Of Intellectual Property – Selected Tax Issues Involving Corporations And Partnerships
This article will review the basic U.S. Federal tax considerations of intellectual prop¬erty ("I.P.") taxation in the context of corporations and partnerships and examine some typical tax considerations...
United States
25 Aug 2017
I.R.S. Breaks The Silence With Rev. Rul. 2017-09, Issues Guidance On "North-South" Transactions
On May 3, 2017, the I.R.S. issued Rev. Rul. 2017-09, 2017-21 I.R.B. 1244, which clarifies "north-south" transactions in two factual situations.
United States
18 Jul 2017
Net Operating Losses: A Valuable Asset Worth Preserving
Every cloud has a silver lining. This expression also applies to the world of tax. Troubled companies that incur significant operational and interest expenses may find that they have generated...
United States
13 Jun 2017
LB&I Audit Insights: Using A Code §6038A Summons When A U.S. Corporation Is 25% Foreign Owned
The I.P.U. acknowledges that exceptions are provided for small corporations and transactions of de minimis value.
United States
11 May 2017
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