CFCs — Foreign Personal Holding Company Income (Portfolio 6220)


Damon Lyon


McDermott Will & Emery LLP


David Noren


McDermott Will & Emery LLP

Lowell Yoder


McDermott Will & Emery LLP

At a glance

I. Introduction
II. Legislative and Regulatory History
III. Overview
IV. General Rules and Definitions
V. Dividends, Interest, Rents, Royalties, and Annuities
VI. Gains from Certain Property Transactions
VII. Commodities Transactions
VIII. Foreign Currency Gains
IX. Income Equivalent to Interest
X. Income from Notional Principal Contracts
XI. Income from Stock Lending Transactions
XII. Income from Personal Service Contracts
XIII. Special Exceptions
XIV. CFC-Owned Partnerships


This Bloomberg Tax Portfolio, CFCs — Foreign Personal Holding Company Income provides a detailed analysis of one of the categories of foreign base company income: foreign personal holding company income, which includes certain dividends, interest, related person factoring income, rents, royalties, income from annuities, commodities transactions, and foreign currency transactions, and certain other income. The other categories of foreign base company income – foreign base company sales income, foreign base company services income, and foreign base company oil related income – are analyzed in detail in related Portfolio 928 T.M., CFCs — Foreign Base Company Income (Other than FPHCI).

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