A recent memo from the IRS's Large Business and International (LB&I) Division indicates an intention to resolve audits efficiently and provide taxpayers with opportunities to quickly settle and resolve issues....more
U.S.-based venture capital and other funds that invest in foreign companies must be careful to avoid the passive foreign investment company (PFIC) rules, which could substantially increase the tax owed on exit for U.S....more
1/9/2020
/ Business Taxes ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Fair Market Value ,
Foreign Corporations ,
GILTI tax ,
Income Taxes ,
Investors ,
IRS ,
Partnerships ,
Passive Investments ,
PFIC ,
Proposed Regulation ,
Startups ,
Subpart F ,
Venture Capital