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50 percent 988 transaction activities allocated amount apply apportioned assets attributable basis capital gains computed Contracting controlled foreign corporation corporation's deduction deemed determined DISC distribution dividend domestic corporation earnings and profits effectively connected election entity example excluded exempt export property filed foreign base company foreign corporation foreign country foreign person foreign tax credit FPHC income functional currency gain or loss gross income gross receipts included income tax investment liability lncome method nonresident alien operations ownership partnership passive income payment personal holding company PFIC Puerto Rico purposes received related person resident rules section 482 sources subpart F income tax rate tax treaty taxable income taxes paid Temp trade or business transaction transfer Treas treated U.S. citizen U.S. corporation U.S. dollars U.S. person U.S. real property U.S. shareholder U.S. tax U.S. taxpayers U.S. trade U.S.-source undistributed United USRPI