New Regulations Issued Regarding CFCs and Investment in U.S. Property
Income earned abroad by U.S. controlled foreign corporations can often qualify for deferral of U.S. income tax. If the foreign corporation is a controlled foreign corporation (CFC), its U.S. shareholders may be taxable on such untaxed income if the corporation converts the property to U.S. property (Code §956).
The U.S. has now issued new and revised regulations . . .