Skip to content 
Foreign companies unintentionally getting caught by US CFC rules
Most tax rules have unintended consequences. That much is obvious. One of the unintended consequences of the Tax Cuts and Jobs Act (TCJA) was the repeal of Section 958(b)(4). It was repealed by TCJA in an effort to narrowly target “de-control” transactions in which a foreign parent of a U.S. shareholder with a CFC sheds the CFC status […]
Foreign companies unintentionally getting caught by US CFC rules Read More »