Offshore Press, Inc.
The International Wealth Protection Monitor
May 22, 2007 -- Volume 3, No. 10

Editor & Publisher: Vernon K. Jacobs,
Editorial Advisors & Correspondents: J. Richard Duke, JD, LLM; Gideon Rothschild, JD, CPA, CFP; Ben Vernazza, CPA, PFS
http://www.offshorepress.com
 The International Wealth Protection Monitor is an email newsletter that reviews current news about asset protection and taxation from dozens of Internet web sites and news sources. Subscriptions are $120/year, which includes access to the Offshore Press On-Line International Wealth Protection Library.

Copyright, 2007, Offshore Press, Inc., All rights reserved. Contact Jacobs1@kc.rr.com  for reprint requirements.

Volume 3, # 10, May. 22, 2007

Table of Contents
Expanded and Updated Third Edition of the Controlled Foreign Corporation Tax Guide

Expanded Third Edition of the
Controlled Foreign Corporation Tax Guide

This issue of the International Wealth Protection Monitor is 186 pages long (8.5 x 11) and is now available on the subscriber's web site.

It is the new, expanded, third edition of our Controlled Foreign Corporation Tax Guide in PDF format.

The file size is 1,195 kb or approximately 1.2 MB.

The new book reflects tax law changes through the end of March, 2007.

As with the first and second editions, our goal is to provide a plain English explanation of the U.S. tax rules that apply to U.S. owners of foreign corporations -- including international business companies (IBC) and foreign limited liability companies that don't make an election to be treated as a disregarded entity for U.S. tax purposes.


We have added an explanation of

  • the disregarded entity election
  • constructive ownership
  • generally accepted accounting principles
  • earnings and profits of a CFC
  • Section 482 and transfer pricing
  • currency conversion issues
  • special rules on various deductions
  • foreign partnerships
  • estate and gift taxes on CFC stock
  • liquidation of a CFC
  • corporate inversions
and we have expanded many other sections.

The guide includes a discussion of the various tax forms that may be required by the U.S. shareholders of a CFC, but it is not intended as a tax preparation manual for the Form 5471 or other related forms.  I've been working on a task force to produce a tax preparation guide for members of the tax division of the AICPA that will hopefully be available to tax division members by mid-summer or early fall.  However, that guide may not be available to anyone who is not a member of the tax division of the AICPA and will have to be secured with the help of a member.

Printed copies of the CFC Tax Guide are not currently available. When they are, the expected retail price will be about $83. Paid subscribers of the International Wealth Protection Library will be able to purchase the printed edition for a 30% discount, which will include shipping in the Continental U.S. via the U.S. postal service.

Changes in the tax laws that affect the contents of the CFC Tax Guide will be described in the International Wealth Protection Monitor.

Vern Jacobs

 

NOTICE - Circular 230 Disclaimer: The information in this newsletter was not intended or written by the authors to be used and cannot be used by any reader for the purpose of avoiding potential penalties that may be imposed for negligence. For further information see Taxpayers vs. Tax Advisors.  The International Wealth Protection Monitor is for paid subscribers to the Offshore Press International Wealth Protection Library.
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