Offshore Tax
Boot Camp
Feb, 2003 - Las Vegas
Tax Rules
for
Controlled Foreign
Corporations
by Vernon Jacobs
- Definition of
a Foreign Corporation
- Nexus, Permanent Establishment
and Domicile
- Definition of a Controlled
Foreign Corporation
- A Non-technical Explanation
of "Subpart F Income"
- Passive Investment
Income of Foreign Corporations
- Related Party Purchases
or Sales
- Related Party Services
Income
- Other "Tainted Income"
(Subpart F Income)
- U.S. Source Income
of Foreign Corporations
- Shareholder Election
to be Taxed as a Domestic Corporation
- Tax Deferral on Foreign
Source Business Income of CFC
- Tax Deferral of Non
Controlled Foreign Corporation Income
- Avoidance of Passive
Foreign Investment Company Treatment
- Attribution and Constructive
Ownership Rules for Foreign Corporations
- Tax on Appreciated
Assets Exchanged for Stock of Foreign Corporation
- Deemed Royalty on Intangibles
Transferred to Foreign Corporations
- Restrictions on Utilization
of Foreign Tax Credit for CFCs
- IRC 367 Gain Election
for Foreign Corporation Shareholders
- Corporate Taxation
in Popular Foreign Jurisdictions
- Some Popular Foreign
Corporation Tax Scams and Schemes
- Tax Filing Obligations
of a Foreign Corporation With U.S. Shareholders
Tax Rules for Offshore Life Insurance
Return to Program Schedule
|