Tag Archives: foreign tax

G Election Trues Up Timing to Recognize CFC & PFIC Income for Net Investment Income Tax

The “G” election,  provided for under U.S. Treas. Reg. Section 1.1411-10(g), impacts U.S. direct and indirect individual shareholders of controlled foreign corporations (“CFCs”) and passive foreign investment companies (“PFICs”). A U.S. individual shareholder of a CFC or PFIC with a qualified electing fund (“QEF”) election is required to report and pay U.S. federal tax on […]

Read more ...

IRS Issues New Transfer Pricing Audit Roadmap

The IRS released a Transfer Pricing Audit Roadmap on February 18, 2014.  The Roadmap, which was issued through the IRS Transfer Pricing Operations of the Large Business and International (LB&I) division, was developed to provide audit techniques and tools for transfer pricing examinations.  The Roadmap is designed as a comprehensive toolkit based on an audit […]

Read more ...

Transfer Pricing – General Principles, Penalties and Contemporaneous Documentation

General Principles – Transfer pricing is relevant for U.S. companies with foreign subsidiaries or foreign parent companies that engage in certain intercompany transactions.  U.S. transfer pricing rules require that intercompany pricing between a U.S. company and a foreign affiliate must be based on an ‘arm’s length’ price that would be charged in a similar transaction […]

Read more ...

View Archives

Blog Authors

Latest Webinar Videos