Chairman Camp's Proposal to Bring the Money Home.
- Published in:
- Financial Executive, 2012, v. 28, n. 2, p. 18
- Publication type:
- Article
Works matching DE "CONTROLLED foreign corporations"
Results: 121
1
2
New Tax Legislation Consequences on U.S. Transfer Pricing and Intangibles.
- Published in:
- Value Examiner, 2018, p. 15
- By:
- Publication type:
- Article
3
Tax Planning for Cross-border Endorsement Payments to Professional U.S. Athletes.
- Published in:
- Florida Bar Journal, 2013, v. 87, n. 8, p. 47
- By:
- Publication type:
- Article
4
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
- By:
- Publication type:
- Article
5
The Application and Analysis of the New Proposed Contract Manufacturing Regulations.
- Published in:
- Florida Bar Journal, 2009, v. 83, n. 1, p. 51
- By:
- Publication type:
- Article
6
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
7
Microsoft's Foreign Earnings: Tax Strategy.
- Published in:
- Issues in Accounting Education, 2015, v. 30, n. 4, p. 297, doi. 10.2308/iace-51177
- By:
- Publication type:
- Article
8
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
- By:
- Publication type:
- Article
9
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
- By:
- Publication type:
- Article
10
International Tax Issues Corner Regulations Focus on U.S. Property Held by CFCS in Partnership Transactions.
- Published in:
- Journal of Passthrough Entities, 2017, v. 20, n. 1, p. 11
- By:
- Publication type:
- Article
11
International Tax Issues Corner.
- Published in:
- Journal of Passthrough Entities, 2014, v. 17, n. 4, p. 21
- By:
- Publication type:
- Article
12
International Tax Issues Corner.
- Published in:
- Journal of Passthrough Entities, 2014, v. 17, n. 3, p. 13
- By:
- Publication type:
- Article
13
International Tax Issues Corner.
- Published in:
- Journal of Passthrough Entities, 2013, v. 16, n. 5, p. 13
- By:
- Publication type:
- Article
14
International Tax Issues Corner.
- Published in:
- Journal of Passthrough Entities, 2011, v. 14, n. 3, p. 13
- By:
- Publication type:
- Article
15
International Tax Issues Corner.
- Published in:
- Journal of Passthrough Entities, 2009, v. 12, n. 4, p. 13
- By:
- Publication type:
- Article
16
International Tax Issues Corner.
- Published in:
- Journal of Passthrough Entities, 2009, v. 12, n. 2, p. 27
- By:
- Publication type:
- Article
17
Offshoring and Transfer of Intellectual Property.
- Published in:
- Information Resources Management Journal, 2010, v. 23, n. 1, p. 74, doi. 10.4018/irmj.2010102605
- By:
- Publication type:
- Article
18
INTERNATIONAL REDEPLOYMENT OF MANAGEMENT PERSONNEL.
- Published in:
- International Journal of Business Insights & Transformation, 2008, v. 1, n. 2, p. 1
- By:
- Publication type:
- Article
19
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
20
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
21
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
22
What Limitations Apply to the CAMT Foreign Tax Credit?
- Published in:
- International Tax Journal, 2024, v. 50, n. 3, p. 18
- By:
- Publication type:
- Article
23
Code Sec. 961 Basis in Inbound Nonrecognition Transactions.
- Published in:
- International Tax Journal, 2024, v. 50, n. 2, p. 3
- By:
- Publication type:
- Article
24
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
25
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
- By:
- Publication type:
- Article
26
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
27
Recent IRS Ruling on a Mid-Year PTEP Distribution.
- Published in:
- International Tax Journal, 2023, v. 49, n. 1, p. 3
- By:
- Publication type:
- Article
28
Treatment of Foreign Stock and Debt Losses: Is It a Total Loss?
- Published in:
- International Tax Journal, 2022, v. 48, n. 6, p. 5
- By:
- Publication type:
- Article
29
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
- By:
- Publication type:
- Article
30
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
31
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
- By:
- Publication type:
- Article
32
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
- By:
- Publication type:
- Article
33
More Anti-Abuse Tools as Dutch Government Announces Strengthening the CFC Rule.
- Published in:
- International Tax Journal, 2022, v. 48, n. 1, p. 31
- By:
- Publication type:
- Article
34
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
- By:
- Publication type:
- Article
35
Apportionment of the Interest Expense of Partnerships and Partners.
- Published in:
- International Tax Journal, 2022, v. 48, n. 1, p. 7
- By:
- Publication type:
- Article
36
The Phoenix Rises--Code Sec. 962 Election Is Back in Vogue.
- Published in:
- International Tax Journal, 2021, v. 47, n. 6, p. 7
- By:
- Publication type:
- Article
37
The Final Code Sec. 267A Regulations and Payments by CFCs.
- Published in:
- International Tax Journal, 2021, v. 47, n. 5, p. 25
- By:
- Publication type:
- Article
38
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
39
Debt Push Downs and the Curious Application of the Debt-Netting Rule.
- Published in:
- International Tax Journal, 2021, v. 47, n. 3, p. 7
- By:
- Publication type:
- Article
40
The Benefits of Subpart F Income.
- Published in:
- International Tax Journal, 2021, v. 47, n. 3, p. 5
- By:
- Publication type:
- Article
41
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
42
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
43
Subpart F Losses.
- Published in:
- International Tax Journal, 2020, v. 46, n. 5, p. 3
- By:
- Publication type:
- Article
44
GILTI Losses.
- Published in:
- International Tax Journal, 2020, v. 46, n. 4, p. 3
- By:
- Publication type:
- Article
45
Constructive Dialogue: BEPS and the TCJA.
- Published in:
- International Tax Journal, 2020, v. 46, n. 2, p. 25
- By:
- Publication type:
- Article
46
U.S. Taxation of "Intangible Income".
- Published in:
- International Tax Journal, 2020, v. 46, n. 1, p. 3
- By:
- Publication type:
- Article
47
Current Developments in International Taxation.
- Published in:
- International Tax Journal, 2019, v. 45, n. 5, p. 37
- By:
- Publication type:
- Article
48
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
49
Final GILTI Regulations: "Tested Income".
- Published in:
- International Tax Journal, 2019, v. 45, n. 5, p. 3
- By:
- Publication type:
- Article
50
To Check or Not to Check? The TCJA's Impact on Entity Classification Decisions.
- Published in:
- International Tax Journal, 2019, v. 45, n. 2, p. 13
- By:
- Publication type:
- Article