Bring That CFC on Home: Domesticating Individually-Owned CFCs After Tax Reform

By and on October 30, 2018

Several changes in tax reform have a disparate impact on non-corporate US shareholders of foreign corporations compared with their corporate counterparts. Many such non-corporate shareholders face an expensive tax increase. They may attempt to mitigate this increase by transferring their shares to a US corporation or making a Section 962 election. This article examines the new rules governing US individuals who own foreign corporations and discusses the most significant recent changes, including a lack of participation exemption for US individuals who own foreign corporations and a higher transition tax rate. It further outlines new options for domestication of such foreign corporations.

Continue Reading.

Originally published in Bloomberg BNA Daily Tax Report – October 26, 2018 – Number 205.

Kevin HallKevin Hall
Kevin Hall focuses his practice on domestic and international tax matters for multinational companies and high-net-worth individuals. Kevin has experience planning and implementing a variety of transactions, including domestic and cross-border mergers, acquisitions, spin-offs, and joint ventures. He has provided tax advice in connection with capital markets transactions and cross-border lending transactions. He has also advised fund sponsors and fund investors. Read Kevin Hall's full bio.


Leigh-Alexandra BashaLeigh-Alexandra Basha
Leigh-Alexandra Basha focuses her practice on domestic and international estate and tax planning. She counsels an affluent international client base on a wide range of sophisticated matters, including estate and trust administration, family wealth preservation, tax compliance, as well as business succession, expatriation and pre-immigration planning. Leigh is head of the Firm’s Washington, DC, Private Client Practice Group. Read Leigh-Alexandra Basha's full bio.

STAY CONNECTED

TOPICS

ARCHIVES