US clarifies branch rules for CFCs

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2025

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Cookies Settings

US clarifies branch rules for CFCs

Matthew Gilleard
December 20 2011
us-irs.jpg

The US IRS and Treasury last week finalised regulations dealing with the branch rules of the Internal Revenue Code, with implications for controlled foreign corporations (CFCs) and their US shareholders.

Unlock this content.

The content you are trying to view is exclusive to our subscribers.

To unlock this content:

Take a Free Trial or Login

Topics

NewsUnited StatesDirect Tax
MG
Matthew Gilleard
Contact
Matthew Gilleard worked at ITR between 2010 and 2016
more across site & shared bottom lb ros

More from across our site

Indirect Tax
USA Brazil
This week in tax: Donald Trump announces 50% tariff on Brazil
The US president also unveiled a new 50% levy on copper imports; in other news, a UK wealth tax proposal has been criticised by the Institute for Fiscal Studies
Sam Sholli, July 11 2025
Direct Tax
wim wuyts 2.jpg
Exclusive: WTS Global CEO steps down
Wim Wuyts, who had been head of the specialist tax network since 2017, is moving on to a new role with WTS’s Belgian member firm
Tom Baker, July 10 2025
Transfer Pricing
Technology ethics
When algorithms decide tax outcomes: embedding ethics in TP systems
MNEs are increasingly using algorithmic tools in TP. Sahasranshu Dash argues that data ethics should therefore plug directly into the TP design process
Sahasranshu Dash , July 10 2025
Transfer Pricing
hmrc.jpg
Experts question whether UK TP proposal is ‘absolutely necessary’
The Institute of Chartered Accountants in England and Wales also queried whether HMRC resources could be better spent scrutinising larger entities
Sam Sholli, July 09 2025
Transfer Pricing
raphael holzinger resized.jpg
‘Coffee is the only constant’: Raphael Holzinger on the pressures of his practice
Grant Thornton’s Austria tax head likens his practice to an escape room, shares his football coaching ambitions, and explains why tax is cool
July 09 2025
Awards
ITR EMEA Tax Awards 2025 4c@4x.png
ITR EMEA Tax Awards 2025: shortlist announced
ITR is delighted to reveal all the shortlisted nominees for the 2025 EMEA Tax Awards
John Harrison, July 08 2025
Awards
apac awards logo 2
ITR APAC Tax Awards 2025: shortlist announced
ITR is delighted to reveal all the shortlisted nominees for the 2025 Asia-Pacific Tax Awards
John Harrison, July 08 2025
Direct Tax
G7 flags
Opinion: G7’s pillar two capitulation proves US power always wins
The fates of pillars one and two hang in the balance after the US successfully threw its weight around in G7 and Canadian negotiations
Tom Baker, July 07 2025
Direct Tax
rafael tena resized.jpg
Mexican tax firm founder ‘won’t sacrifice quality for size’
Rafael Tena tells ITR about the ‘crazy’ Mexican market, ditching the hourly rate, and refusing to grow his fledgling firm in an ‘unstructured way’
Tom Baker, July 07 2025
Direct Tax
UK Cost Transparency Troubles (1).png
UK tax adviser ‘shocked’ at in-house costs criticism
It should be easy for advisers to be transparent about costs, Brown Rudnick partner Matthew Sharp said in response to exclusive ITR in-house data
Tom Baker, July 04 2025
Gift this article