Works matching DE "CONTROLLED foreign corporations"

Results: 121

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

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:

Weiss, Mitchell B.;
Trevick, Jacob S.

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

By:

Skinner, William;
Ushakova-Stein, Julia

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

By:

Kloprogge, Robert Jean;
Elsenburg, Olivier

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

By:

de Ruig, David;
Becker, Adam

Publication type:

Article

Apportionment of the Interest Expense of Partnerships and Partners.

Published in:

International Tax Journal, 2022, v. 48, n. 1, p. 7

By:

Lokken, Lawrence

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

By:

Cornett, J. Michael

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

By:

Lockhart, Jonathan D.;
Noren, David G.

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:

Kaywood, Sam K.

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

By:

Skinner, William

Publication type:

Article

The Benefits of Subpart F Income.

Published in:

International Tax Journal, 2021, v. 47, n. 3, p. 5

By:

Yoder, Lowell D.

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:

Jenn, Brian

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:

Skinner, William

Publication type:

Article

Subpart F Losses.

Published in:

International Tax Journal, 2020, v. 46, n. 5, p. 3

By:

Yoder, Lowell D.

Publication type:

Article

GILTI Losses.

Published in:

International Tax Journal, 2020, v. 46, n. 4, p. 3

By:

Yoder, Lowell D.

Publication type:

Article

Constructive Dialogue: BEPS and the TCJA.

Published in:

International Tax Journal, 2020, v. 46, n. 2, p. 25

By:

Avi-Yonah, Reuven S.

Publication type:

Article

U.S. Taxation of "Intangible Income".

Published in:

International Tax Journal, 2020, v. 46, n. 1, p. 3

By:

Yoder, Lowell D.

Publication type:

Article

Current Developments in International Taxation.

Published in:

International Tax Journal, 2019, v. 45, n. 5, p. 37

By:

Huanyu Ouyang;
Yang, James G. S.

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:

Lokken, Lawrence

Publication type:

Article

Final GILTI Regulations: "Tested Income".

Published in:

International Tax Journal, 2019, v. 45, n. 5, p. 3

By:

Yoder, Lowell D.

Publication type:

Article

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:

Spinowitz, Moshe;
Stevenson, Robert C.

Publication type:

Article

Implementation in Luxembourg of the EU Anti-Tax Avoidance Directive.

Published in:

International Tax Journal, 2018, v. 44, n. 6, p. 29

By:

Neugebauer, Jan;
Lesage, Thierry

Publication type:

Article

A Comprehensive Approach to GILTI Planning for Individuals and Trusts.

Published in:

International Tax Journal, 2018, v. 44, n. 6, p. 9

By:

Hadjilogiou, Steven;
Hall, Kevin;
Le Chen

Publication type:

Article

The High-Taxed Exception and E&P Limitation to Subpart F Income.

Published in:

International Tax Journal, 2018, v. 44, n. 6, p. 5

By:

Skinner, William

Publication type:

Article

A Few GILTI Planning Tips.

Published in:

International Tax Journal, 2018, v. 44, n. 6, p. 3

By:

Yoder, Lowell D.

Publication type:

Article

100% DRD for CFC Dividends.

Published in:

International Tax Journal, 2018, v. 44, n. 4, p. 3

By:

Yoder, Lowell D.

Publication type:

Article

GILTI Rules Particularly Onerous for Non-C Corporation CFC Shareholders.

Published in:

International Tax Journal, 2018, v. 44, n. 1, p. 11

By:

McGill, Sandra P.;
Karch, Gary C.;
Feeley, Kevin J.;
O'Banion, Susan E.;
Crouse, Justin G.

Publication type:

Article

Non-Subpart F Sales Income: Employee Substance Generally Is Not a Requirement.

Published in:

International Tax Journal, 2017, v. 43, n. 5, p. 3

By:

YODER, LOWELL D.

Publication type:

Article

A Decade of Shooting Itself in the Foot: The IRS's Battle Against the Killer B.

Published in:

International Tax Journal, 2017, v. 43, n. 3, p. 5

By:

Stevenson, Robert C.

Publication type:

Article

Subpart F: When Is Services Income Analyzed as Sales Income?

Published in:

International Tax Journal, 2016, v. 42, n. 1, p. 3

By:

YODER, LOWELL D.

Publication type:

Article

Application of Tax on Net Investment Income to Shareholders of CFCs and PFICs.

Published in:

International Tax Journal, 2014, v. 40, n. 5, p. 15

By:

Lokken, Lawrence

Publication type:

Article

Voluntary Payment of Foreign Income Tax for Adjustments That Do Not Change Taxable Income.

Published in:

International Tax Journal, 2014, v. 40, n. 4, p. 5

By:

Riedy, James A.;
McGill, Sandra

Publication type:

Article

No Subpart F Income if No Related Party Purchase or Sale of Products.

Published in:

International Tax Journal, 2014, v. 40, n. 4, p. 3

By:

YODER, LOWELL D.

Publication type:

Article

Recent LTRs Apply Subpart F Manufacturing Exceptions.

Published in:

International Tax Journal, 2014, v. 40, n. 2, p. 3

By:

Yoder, Lowell D.

Publication type:

Article

International Partnerships, Joint Ventures and Hybrids.

Published in:

International Tax Journal, 2014, v. 40, n. 1, p. 5

By:

Osterberg Jr, Edward C.

Publication type:

Article

Subpart F: Hedging Currency Risk in a Branch Context.

Published in:

International Tax Journal, 2012, v. 38, n. 6, p. 33

By:

Shore, Jeffrey L.

Publication type:

Article

Outbound Asset Transfers.

Published in:

International Tax Journal, 2012, v. 38, n. 2, p. 15

By:

Cornett, Michael;
Reedy, Adam

Publication type:

Article

A Note From the Editor-in-Chief.

Published in:

International Tax Journal, 2012, v. 38, n. 2, p. 3

By:

Yoder, Lowell D.

Publication type:

Article

Following Through on Notice 2007-13: Suggestions for Updating the Sub F Services Regulations.

Published in:

International Tax Journal, 2011, v. 37, n. 6, p. 27

By:

Sotos, David;
Stenger, Allen;
Stevenson, Robert

Publication type:

Article

Intercompany Royalties: Foreign Tax Credit Category.

Published in:

International Tax Journal, 2011, v. 37, n. 6, p. 3

By:

Yoder, Lowell D.

Publication type:

Article

A Note From the Editor-in-Chief.

Published in:

International Tax Journal, 2011, v. 37, n. 3, p. 3

By:

Yoder, Lowell D.

Publication type:

Article

A Note From the Editor-in-Chief.

Published in:

International Tax Journal, 2011, v. 37, n. 1, p. 3

By:

Yoder, Lowell D.

Publication type:

Article

A Note From the Editor-in-Chief.

Published in:

International Tax Journal, 2010, v. 36, n. 5, p. 3

By:

Lowell D. Yoder

Publication type:

Article

Schering-Plough--Failing to Apply the IRS's Position on Conduits for Purposes of Code Sec. 956.

Published in:

International Tax Journal, 2010, v. 36, n. 4, p. 47

By:

Feldgarden, Robert

Publication type:

Article

The Application of the Branch Rule to Partnerships.

Published in:

International Tax Journal, 2010, v. 36, n. 4, p. 55

By:

Neumann, Larissa B.

Publication type:

Article

Dual Consolidated Losses.

Published in:

International Tax Journal, 2010, v. 36, n. 4, p. 11

By:

Halpern, Irwin;
Trump, Chris

Publication type:

Article

Spinning Out of a Sandwich Structure-IRS Provides Favorable Code Sec. 355 Rulings.

Published in:

International Tax Journal, 2010, v. 36, n. 3, p. 33

By:

Calianno, Joseph;
Hogan, Margaret

Publication type:

Article

International Partnerships, Joint Ventures and Hybrids.

Published in:

International Tax Journal, 2010, v. 36, n. 3, p. 17

By:

Osterberg Jr., Edward C.

Publication type:

Article

Ireland: Corporate Migrations to Ireland.

Published in:

International Tax Journal, 2010, v. 36, n. 1, p. 25

By:

Hickson, John

Publication type:

Article

Redeploying Foreign Cash from the United States.

Published in:

International Tax Journal, 2010, v. 36, n. 2, p. 3

By:

Yoder, Lowell D.

Publication type:

Article