CFCs--foreign personal holding company income [electronic resource] / Lowell D. Yoder, Damon M. Lyon, David G. Noren.
" ... analyzes the rules for U.S. federal income taxation of United States shareholders of controlled foreign corporations (CFCs) under "Subpart F" of the Internal Revenue Code. This Portfolio provides a detailed analysis of one of the categories of foreign base company income: foreig...
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| Online Access: |
Law Students, Faculty, and Staff (via Bloomberg Law) |
|---|---|
| Main Author: | |
| Corporate Author: | |
| Other Authors: | , |
| Other title: | Controlled foreign companies--foreign personal holding company income Foreign personal holding company income Bloomberg Law online Bloomberg Law online. |
| Format: | Electronic Website |
| Language: | English |
| Published: |
Arlington, VA :
Tax Management Incorporated,
[2004]-
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| Series: | Tax management portfolios ;
6220. |
| Subjects: |
Table of Contents:
- Detailed analysis. Introduction
- Legislative and regulatory history
- Overview
- General rules and definitions
- Dividends, interest, rents, royalties and annuities
- Gains from certain property transactions
- Commodities transactions
- Foreign currency gains
- Income equivalent to interest
- Income from notional principal contracts
- Income from stock lending transactions
- Income from personal service contracts
- Special exceptions
- CFC-owned partnerships
- Working papers.