Applying the Subpart F Services Rules to Regarded Entity Structures

Overview


In Depth


Lowell Yoder wrote this bylined article as a follow-up to an earlier one on conducting services operations in a disregarded entity structure under a foreign holding company to minimize Subpart F income. Here he discussed how a regarded entity structure can reduce Subpart F services income when substantial services are deemed performed for related persons, concluding that income derived by each controlled foreign corporation should not be Subpart F services income to the extent the CFC performs any related-person services in its country of organization. Read the full article.