Portfolios

International Tax

Nearly 100 Tax Management Portfolios™ provide practical analysis in virtually any scenario involving U.S. taxation of cross-border transactions — from foreign tax credits and branch profits tax to foreign partners and partnerships and Subpart F Corporations.

International Tax

CFCs — Foreign Base Company Income (Other than FPHCI) (Portfolio 6240)

This Portfolio focuses on the provisions of §954 other than those pertaining to foreign personal holding company income.

International Tax

CFCs — Foreign Personal Holding Company Income (Portfolio 6220)

This Portfolio provides a analysis of foreign personal holding company income, foreign base company income and "Subpart F income".

International Tax

CFCs — Investment of Earnings in United States Property (Portfolio 6260)

This portfolio analyzes the U.S. income tax consequences under §956 of the Internal Revenue Code of investment.

International Tax

CFCs — Sections 959-965 and 1248 (Portfolio 930)

This Portfolio describes the rules that apply to the repatriation of the earnings and profits of a CFC under Subpart F of the Internal Revenue Code.

International Tax

CFCs—General Overview (Portfolio 926)

This Portfolio describes the rules for the U.S. federal income taxation of shareholders of controlled foreign corporations (CFCs) under Subpart F of the Internal Revenue Code.

International Tax

Collateralized Loan Obligations (Portfolio 6585)

This Portfolio describes the taxation of collateralized loan obligation issuers (CLOs) and their investors.

International Tax

Dual Consolidated Loses (Portfolio 6650)

This Portfolio provides a detailed description of the limitations imposed for federal income tax purposes on the use of a single economic loss twice.

International Tax

Export Tax Incentives (Portfolio 6360)

This Portfolio discusses the rules pertaining to interest-charge domestic international sales corporations (IC DISCs), which currently constitute one of the two remaining export tax incentives under the Internal Revenue Code of 1986, as amended.

International Tax

FATCA — Information Reporting and Withholding Under Chapter 4 (Portfolio 6565)

This Portfolio discusses the reporting and withholding requirements of chapter 4 (§1471–§1474) of the Internal Revenue Code.

International Tax

Foreign Corporation Earnings and Profits (Portfolio 932)

This Portfolio explains how the earnings and profits (E&P) of foreign corporations are computed, accounted for, and applied for U.S. tax purposes.
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