Tax Reform Series 46 – Other Subpart F Changes

Plain Language of Change:

  • Repeals of section 955, which required an inclusion of qualified foreign base company shipping operations.

  • Repeals foreign base company oil related income as a category of foreign base company income, i.e., subpart F income

  • Modifies the stock attribution rules of section 958(b) for determining CFC status so that certain stock of a foreign corporation owned by a foreign person is attributed to a related U.S. person for purposes of determining whether the related U.S. person is a U.S. taxpayer (i.e., providing for “downward attribution”). This provision is intended to render ineffective certain transactions that are used as a means of avoiding the subpart F provisions

  • Expands the definition of U.S. shareholder under subpart F to include any U.S. person who owns 10 percent or more of the total value of shares of all classes of stock of a foreign corporation

  • Eliminates the requirement that a corporation must be controlled for 30 days before the subpart F inclusions apply

Detailed Analysis of Other Subpart F Changes

Cordasco & Company PC is a boutique CPA firm specializing in federal and state tax issues. We provide customized tax and accounting services specifically designed to help our clients capitalize on the rapidly changing tax and accounting environments.

This entry was posted in Blog and tagged , , . Bookmark the permalink.

Comments are closed.