This content is from: United States

New guidance on controlled foreign corporations earnings in the US

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.

To access our market-driven intelligence please request a trial here.

Read this article – and more – for a 30 day period.

REQUEST ACCESS

Are you already an ITR subscriber? Log in here

Instant access to all of our content. Membership Options | 30 Day Trial

Related