Works matching DE "CONTROLLED foreign corporations"
Results: 120
Reframing the Questions Surrounding the Application of Code Sec. 245A to Controlled Foreign Corporations.
- Published in:
- International Tax Journal, 2025, v. 51, n. 1, p. 22
- By:
- Publication type:
- Article
Notice 2008-91, Treatment of Certain CFC Obligations under Section 956 of the Internal Revenue Code.
- Published in:
- Tax Executive, 2008, v. 60, n. 6, p. 453
- Publication type:
- Article
Virtual Manufacturing and the Proposed Contract Manufacturing Regulations.
- Published in:
- Tax Executive, 2008, v. 60, n. 4, p. 255
- By:
- Publication type:
- Article
Repatriation Guidance -- Part 2: Notice 2005-38 Clarifies Critical Issues.
- Published in:
- Tax Executive, 2005, v. 57, n. 3, p. 252
- By:
- Publication type:
- Article
Section 1248(b): The individual Limitation on Taxing Sales of CGC Stock Offers Substantial Tax Savings.
- Published in:
- Journal of the American Taxation Association, 1981, v. 2, n. 2, p. 20
- By:
- Publication type:
- Article
INTERNATIONAL REDEPLOYMENT OF MANAGEMENT PERSONNEL.
- Published in:
- International Journal of Business Insights & Transformation, 2008, v. 1, n. 2, p. 1
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- Publication type:
- Article
KONTROL EDİLEN YABANCI KURUM KAZANCININ ZARARLI VERGİ REKABETİNE ETKİSİ.
- Published in:
- Financial Analysis / Mali Cozum Dergisi, 2013, n. 119, p. 163
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- Publication type:
- Article
Propping through related party transactions.
- Published in:
- Review of Accounting Studies, 2010, v. 15, n. 1, p. 70, doi. 10.1007/s11142-008-9081-4
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- Publication type:
- Article
Chairman Camp's Proposal to Bring the Money Home.
- Published in:
- Financial Executive, 2012, v. 28, n. 2, p. 18
- Publication type:
- Article
International Tax Controversies.
- Published in:
- Journal of Taxation of Global Transactions, 2006, v. 6, n. 3, p. 23
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- Publication type:
- Article
The Impact of Code Sec. 951(a)(2)(B) on Subpart F.
- Published in:
- Journal of Taxation of Global Transactions, 2006, v. 6, n. 3, p. 51
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- Publication type:
- Article
A Note From the Editor-in-Chief.
- Published in:
- Journal of Taxation of Global Transactions, 2006, v. 6, n. 3, p. 3
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- Publication type:
- Article
On Jabberwocky, Tumtum Trees and the Active Financing Exception to Subpart F.
- Published in:
- Journal of Taxation of Financial Products, 2008, v. 7, n. 2, p. 25
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- Publication type:
- Article
The taxation of controlled foreign corporations: An international comparison.
- Published in:
- 1987
- Publication type:
- Book Review
Joined Cases C-443/14 and C-444/14 Kreis Warendorf v Ibrahim Alo and Amira Osso v Region Hannover (Judgment of the Court of Justice, Grand Chamber, 1 March 2016).
- Published in:
- International Journal of Refugee Law, 2016, v. 28, n. 3, p. 493, doi. 10.1093/ijrl/eew052
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- Publication type:
- Article
IDENTITY, COMMUNITY, AND AUDIENCE: HOW WHOLLY OWNED FOREIGN SUBSIDIARIES GAIN LEGITIMACY IN CHINA.
- Published in:
- Academy of Management Journal, 2007, v. 50, n. 1, p. 175, doi. 10.5465/AMJ.2007.24162209
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- Publication type:
- Article
X‐GmbH v Finanzamt Stuttgart – Körperschaften: Abuse of Tax Law and Exchange of Tax Information in EU law.
- Published in:
- Modern Law Review, 2022, v. 85, n. 2, p. 488, doi. 10.1111/1468-2230.12665
- Publication type:
- Article
Final Guidance on Transfer Pricing Released by the OECD.
- Published in:
- Journal of Corporate Accounting & Finance (Wiley), 2016, v. 27, n. 3, p. 97, doi. 10.1002/jcaf.22149
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- Publication type:
- Article
IRS Takes Controversial Approach to Characterization of Separately Stated Item of Subpart F Income.
- Published in:
- Florida Bar Journal, 2009, v. 83, n. 10, p. 29
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- Publication type:
- Article
The Application and Analysis of the New Proposed Contract Manufacturing Regulations.
- Published in:
- Florida Bar Journal, 2009, v. 83, n. 1, p. 51
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- Publication type:
- Article
Moving the "Management and Control" of a Foreign Corporation to Achieve Favorable U.S. Tax Results Part II.
- Published in:
- Florida Bar Journal, 2007, v. 81, n. 10, p. 44
- By:
- Publication type:
- Article
Testing PFIC Status: Recent Regulations Raise Traps for the Unwary in Applying the Asset Test Rules.
- Published in:
- International Tax Journal, 2024, v. 50, n. 5, p. 6
- By:
- Publication type:
- Article
Claiming Foreign Tax Credits Arising from Never-Ending Foreign Audits--An Overview.
- Published in:
- International Tax Journal, 2024, v. 50, n. 5, p. 3
- By:
- Publication type:
- Article
What Limitations Apply to the CAMT Foreign Tax Credit?
- Published in:
- International Tax Journal, 2024, v. 50, n. 3, p. 18
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- Publication type:
- Article
Code Sec. 961 Basis in Inbound Nonrecognition Transactions.
- Published in:
- International Tax Journal, 2024, v. 50, n. 2, p. 3
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- Publication type:
- Article
Blurry Views from the Look-Through Glass: Application of Code Sec. 954(c)(6) to Payments Out of High-Taxed Earnings and to Payments from Faux CFCs.
- Published in:
- International Tax Journal, 2024, v. 50, n. 1, p. 7
- By:
- Publication type:
- Article
Reconsidering the PFIC Asset Test Adjusted-Basis Requirement's Application to CFCs Held by Domestic Partnerships.
- Published in:
- International Tax Journal, 2023, v. 49, n. 3, p. 11
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- Publication type:
- Article
IRS Proposes Further Limits on the "Pro Rata Share" Rule of Code Sec. 951(a)(2)(B).
- Published in:
- International Tax Journal, 2023, v. 49, n. 1, p. 5
- By:
- Publication type:
- Article
Recent IRS Ruling on a Mid-Year PTEP Distribution.
- Published in:
- International Tax Journal, 2023, v. 49, n. 1, p. 3
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- Publication type:
- Article
Treatment of Foreign Stock and Debt Losses: Is It a Total Loss?
- Published in:
- International Tax Journal, 2022, v. 48, n. 6, p. 5
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- Publication type:
- Article
The Elusive Nature of Code Sec. 961(c) Basis in a Post-TCJA Multiverse.
- Published in:
- International Tax Journal, 2022, v. 48, n. 5, p. 47
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- Publication type:
- Article
No One Is Doing Inversions Anymore, So Why Does Code Sec. 7874 Apply to My Deal?
- Published in:
- International Tax Journal, 2022, v. 48, n. 4, p. 23
- By:
- Publication type:
- Article
The All Earnings and Profits Amount of a Domesticating Foreign Target: The Non-Recognition Cleansing Exception.
- Published in:
- International Tax Journal, 2022, v. 48, n. 3, p. 5
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- Publication type:
- Article
Important Subpart F and PFIC Changes for U.S. Investors and Domestic Funds.
- Published in:
- International Tax Journal, 2022, v. 48, n. 2, p. 45
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- Publication type:
- Article
More Anti-Abuse Tools as Dutch Government Announces Strengthening the CFC Rule.
- Published in:
- International Tax Journal, 2022, v. 48, n. 1, p. 31
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- Publication type:
- Article
Start with When: Navigating When (and by Whom) Foreign Income Taxes Accrue for Purposes of the U.S. Foreign Tax Credit Rules.
- Published in:
- International Tax Journal, 2022, v. 48, n. 1, p. 19
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- Publication type:
- Article
Apportionment of the Interest Expense of Partnerships and Partners.
- Published in:
- International Tax Journal, 2022, v. 48, n. 1, p. 7
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- Publication type:
- Article
The Phoenix Rises--Code Sec. 962 Election Is Back in Vogue.
- Published in:
- International Tax Journal, 2021, v. 47, n. 6, p. 7
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- Publication type:
- Article
The Final Code Sec. 267A Regulations and Payments by CFCs.
- Published in:
- International Tax Journal, 2021, v. 47, n. 5, p. 25
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- Publication type:
- Article
Taxable Acquisitions of Foreign Corporations During a Pandemic (of Change).
- Published in:
- International Tax Journal, 2021, v. 47, n. 5, p. 7
- By:
- Publication type:
- Article
Debt Push Downs and the Curious Application of the Debt-Netting Rule.
- Published in:
- International Tax Journal, 2021, v. 47, n. 3, p. 7
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- Publication type:
- Article
The Benefits of Subpart F Income.
- Published in:
- International Tax Journal, 2021, v. 47, n. 3, p. 5
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- Publication type:
- Article
How to Lose a Foreign Tax Credit, Part I: Disregarded Transactions of a CFC.
- Published in:
- International Tax Journal, 2021, v. 47, n. 2, p. 27
- By:
- Publication type:
- Article
New Considerations in Taxation of Foreign Exchange Transactions After the 2017 Act.
- Published in:
- International Tax Journal, 2020, v. 46, n. 5, p. 21
- By:
- Publication type:
- Article
Subpart F Losses.
- Published in:
- International Tax Journal, 2020, v. 46, n. 5, p. 3
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- Publication type:
- Article
GILTI Losses.
- Published in:
- International Tax Journal, 2020, v. 46, n. 4, p. 3
- By:
- Publication type:
- Article
Constructive Dialogue: BEPS and the TCJA.
- Published in:
- International Tax Journal, 2020, v. 46, n. 2, p. 25
- By:
- Publication type:
- Article
U.S. Taxation of "Intangible Income".
- Published in:
- International Tax Journal, 2020, v. 46, n. 1, p. 3
- By:
- Publication type:
- Article
Current Developments in International Taxation.
- Published in:
- International Tax Journal, 2019, v. 45, n. 5, p. 37
- By:
- Publication type:
- Article
Code Sec. 956 and the Deduction for Dividends Received.
- Published in:
- International Tax Journal, 2019, v. 45, n. 5, p. 13
- By:
- Publication type:
- Article