Controlled Foreign Corporation ("CFC") Archives

Whistleblowers and The Global Reach of The IRS and NYS.

Recent headlines and articles in the financial press have been rich with inflammatory buzz words referencing “whistleblower payouts”, “indictments for tax evasion”, “state & local tax enforcement”, renewed threats of…

March 4, 2021

Controlled Foreign Corporation ("CFC") Foreign Tax Preparation Forms and Filings Internal Revenue Code Internal Revenue Service Tax Compliance

Dormant Foreign Corporations

A Controlled Foreign Corporation (“CFC”) is, in general, a foreign corporation controlled by a U.S. person(s) through ownership of stock. A U.S. person owning at least 10% of a CFC has a…

December 15, 2016

Argentina Blocked Income Controlled Foreign Corporation ("CFC") Foreign Tax Preparation Forms and Filings International Taxation Subpart F Income

Tax Consequences of Blocked Income in Foreign Countries

Some countries put restrictions on currency, effectively ‘blocking the income’ from being readily convertible into other currencies, including U.S. dollars. Such currency control was recently in place in Argentina, where…

January 14, 2016

Category: Controlled Foreign Corporation (“CFC”)

Whistleblowers and The Global Reach of The IRS and NYS.

Dormant Foreign Corporations

Tax Consequences of Blocked Income in Foreign Countries

Christopher J. Byrne PLLC

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