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In general, a CFC is a foreign corporation that is more than 50 percent owned (directly, indirectly or constructively) by “U. shareholders.” Subpart F income includes most forms of passive income (e.g., interest, dividends, royalties, capital gains, etc.), as well as income from related party sales and service transactions that have little, if any, connection with the CFC’s country of incorporation.

shareholder” of a controlled foreign corporation (CFC) is required to include in its gross income its pro rata share of a CFC’s “subpart F” income, regardless of whether such income is distributed.

If, however, the foreign corporation is a CFC and the foreign-source ECI also gives rise to subpart F income (which it likely would), the subpart F rules will trump the ECI rules, regardless of whether any amount is taxable in the hands of a U.

S.-source ECI, there are certain categories of foreign-source income that can be treated as ECI under Section 864(c)(4)(B).

Accordingly, it may be possible for a foreign corporation that is owned by foreign persons and that is subject to U. federal income tax on foreign-source ECI to interpose a U. partnership in between the corporation and its foreign shareholders to take advantage of the CFC trumping rule, without actually triggering any U. In this situation, the liquidating distribution generally will be exempt from U. However, those arguments typically are much more difficult to sustain.

Under Section 332(d), a liquidating distribution to a foreign corporation of an “applicable holding company” is treated as a dividend (rather than non-taxable income) that generally will be subject to a 30 percent U. An exception exists, however, if the foreign corporation is a CFC. Therefore, it may be possible to convert taxable dividend income into a non-taxable distribution by interposing a U. partnership in between the foreign corporation and its shareholders to cause such foreign corporation to be characterized as a CFC. This may be because the partnership anti-abuse rules themselves contain an example that approves the interposition of a U. partnership in between the shareholders and a foreign corporation for the sole purpose of converting the foreign corporation into a CFC, which would allow the shareholders to take advantage of more favorable foreign tax credit provisions. Other possible avenues of attack include the use of judicial doctrines, such as substance over form, sham transaction and economic substance.

forms for liquidating an s corporation-87forms for liquidating an s corporation-29forms for liquidating an s corporation-22

He is the founder of North Country Capital, an investment and advisory firm where he currently serves as President. Doheny served as a Managing Director and helped lead the Distressed Products Group of Deutsche Bank Securities Inc. Prior to Deutsche Bank, he was a bankruptcy attorney in the corporate reorganization groups of Orrick and Kelley Drye. Doheny currently serves on the boards of YRC Worldwide Inc, Affinity Gaming, Arcapita Inc (RA Holdings) and Eastman Kodak Inc. After his time at Price Waterhouse, he served as a Senior Managing Director at FTI Consulting. Weber has served on the Contra Costa Civil Grand Jury, performed occasional independent consulting projects and assumed board/trustee positions. Weber currently serves on Board of Directors of winery Truett Hurst, Inc., and chairs the audit committee. While the IRS has challenged the affirmative use of U. partnerships in the outbound context when the foreign partners themselves are CFCs with U. Planning Opportunities This disparity in treatment may lead to a number of interesting tax planning opportunities when structuring inbound investments into the United States. In general, an applicable holding company is a domestic corporation that (i) has been in existence for less than 5 years and (ii) substantially all of its assets consist of stock in other members of an affiliated group. It is interesting to note, however, that in Notice 2010-41 decided against the use of these provisions, but instead selectively chose to treat the U. partnership as a foreign partnership to prevent the purported abuse. partnerships in these situations, it would seem that the most likely scenario would be an attack under the partnership anti-abuse rules.




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