In the News

8/2016

CFC Decontrol in Light of Proposed Regulation 385

  • picture of Severiano E. Ortiz
    Severiano E. Ortiz

This presentation discusses the basics of a controlled foreign corporation and the complications of de-controlling it with respect to Proposed Regulation 385, local country constraints, and the impact of section 367(b) and 904(f). PwC US International Tax Services Business Development Meeting. August 11, 2016.

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