Tag Archives: CFC
Possible Techniques for Transferring IP Offshore
For companies with significant Intellectual Property (IP), it may be beneficial for tax purposes to consider transferring its IP to a controlled foreign entity. The rules and regulations are complicated, so we thought it would be of value to outline … Continue reading
Will Congress OK a repatriation holiday?
Under current law, if a corporation has off shore earnings those amounts are generally not subject to US income tax until they are repatriated (brought back) to the US. We are strong advocates for non-US earned income being allowed to be … Continue reading
Posted in Blog, Featured on Homepage, Foreign Income, Tax Planning
Tagged CFC, Foreign Activity, Foreign Income, Tax Planning
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Good News for Some Software Providers
In Chief Counsel Advice (CCA), IRS has concluded that the sale of software products by a controlled foreign corporation (CFC) to U.S. end-user customers did not constitute an investment in U.S. property.
Posted in Blog, Foreign Income, Tax Notes, Tax Planning
Tagged CFC, Foreign Income, small business, tax, Tax Planning, Tax Reporting
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