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

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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

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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.

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