Expansion of Subpart F under the Tax Reform Act

Overview


Lowell Yoder, David Noren and Elizabeth Chao wrote this bylined article describing how the new tax law increased the amount of controlled foreign corporation (CFC) income currently taxable to US shareholders, and expanded the CFC ownership rules to treat more foreign corporations as CFCs. The authors urged US taxpayers that own shares in foreign corporations to study the new rules and consider operating structure changes that can limit additional tax costs.