Subpart F income requires U.S. shareholders of controlled foreign corporations to report certain categories of foreign income — even when no distribution is made. This article explains how Subpart F ...

A perplexing attribute of the U.S. tax system is that successive reform efforts tend to layer new regimes on top of old ones without bothering to repeal the latter. It’s as if retention of the older ...

Income derived by a foreign corporation—including a foreign corporation owned by US shareholders—from conducting operations outside the United States has not generally been subject to US taxation.