Tax Planning, Internal Revenue Code (IRC), Foreign Corporations

Taxpayer Beware: The Pitfalls of Section 965 Installment Payments

Lippes Mathias LLP on 3/31/2025

For the taxable years ending on December 31, 2017, and 2018, Section 965[1] of the Internal Revenue Code required U.S. shareholders (as defined in Section 951(b)) to pay a transition tax on the untaxed foreign earnings of...more

Section 883 Tax Exemption for Cargo Shipping and Cruise Lines At Risk?

Seward & Kissel LLP on 2/24/2025

Last week, speaking on Fox News, Commerce Secretary Howard Lutnick appeared to threaten the repeal of the exemption under Section 883 of the Internal Revenue Code for foreign corporations engaged in the international...more

U.S. Department of Treasury’s Proposed PTEP Regulations: Key Changes and Tax Implications

Fenwick & West LLP on 2/6/2025

The U.S. Department of Treasury (Treasury) recently released proposed regulations under §§ 959 and 961 and related Code sections (REG-105479-18, the “Proposed Regulations”) addressing the treatment of previously taxed...more

Certain Canadian Corporations May Unknowingly be Subject to U.S. Federal Backup Withholding and Reporting Requirements With...

Dorsey & Whitney LLP on 1/31/2025

Canadian corporations making dividend payments should ensure that they are compliant with U.S. federal backup withholding and reporting requirements to avoid potential U.S. federal income tax issues....more

Reviewing a Foreign Legal Structure

Freeman Law on 1/25/2023

Why You Should Hire a Tax Professional to Review Your Foreign Legal Structure - U.S. parented corporations that have foreign operations conducted through a foreign legal structure have significant U.S. tax filing and...more

Gain Recognition Agreements and Outbound Stock Transfers

Freeman Law on 11/11/2022

GRAs and Section 367(a)(1) Outbound Stock Transfer Rules Overview - Introduction to Section 367(a)(1), Outbound Stock Transfers, and Gain Recognition Agreements - Section 367(a) of the Internal Revenue Code (the “Code”)...more

Navigating the Branch Profits Tax

Freeman Law on 4/1/2022

The Branch Profits Tax - The branch profits tax is imposed on foreign corporations engaged in a U.S. trade or business through a branch, rather than a subsidiary. The branch profits tax is imposed in addition to any tax on...more

Income Sourcing Rules – Foreign-Source and U.S.-Source Income

Freeman Law on 3/21/2022

In the international tax context, the source of a taxpayer’s income can have significant implications. The source of income may determine whether a taxpayer qualifies for a foreign tax credit with respect to the income. Or,...more

The Tax Court in Brief – TBL Licensing LLC v. Commissioner

Freeman Law on 2/14/2022

Tax Litigation: The Week of February 7 – February 11, 2022 Williams v. Commissioner Sloane v. Commissioner TBL Licensing LLC v. Comm’r, Corrected 158 T.C. 1 | February 8, 2022 | Filed January 31, 2022 | Halpern, J. | Dkt. No....more

Are there conflicting signals from IRS as it relates to Section 965?

Foodman CPAs & Advisors on 2/7/2020

IRC Section 965 (Treatment of Deferred Foreign Income Upon Transition to Participation Exemption System of Taxation) was part of the TCJA enacted on December 22, 2017. ...more

U.S. Individuals Electing To Be Treated As Corporations: American Werewolves?

Farrell Fritz, P.C. on 3/19/2019

The Tax Cuts and Jobs Act has been called a lot of things by a lot of different people. Certain provisions of the Act, however,coupled with recently proposed regulations thereunder, may result in its being known as the...more

U.S. Tax Reform: Impacts and Opportunities for Mexican Businesses, Part 1 - A General Overview on Issues That U.S. and Mexican...

Holland & Knight LLP on 7/23/2018

• The Tax Cuts and Jobs Act (Tax Act), signed into law on Dec. 22, 2017, made significant changes to the manner in which U.S. corporate and individual taxpayers are taxed on income from international operations. • The Tax...more

Tax Planning › Internal Revenue Code (IRC) › Foreign Corporations

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