New guidance on controlled foreign corporations earnings in the US

August 07 2004

The US Treasury and the Internal Revenue Service issued proposed regulations last Thursday providing guidance for determining a US shareholder’s pro rata share of income for controlled foreign corporations (CFCs) under the subpart F rules. The proposed regulations provide detailed rules on distributions of earnings when a CFC has multiple classes of stock. When issued in final form the regulations will be effective for tax years beginning January 1 2005.

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