SERVICE OFFERING:

Controlled Foreign Corporation ("CFC") Tax Planning

There are many attractive investments internationally. U.S. tax residents need to consider if their investment may be subject to the CFC rules. CFC rules may apply when U.S. persons collectively own certain voting or value interests in foreign corporations.

Issues to Consider

Would an alternative structure

reduce the risk of CFC status?

What are the required U.S. tax

 disclosures if the investment is

 regarded as a CFC?

Is my investment considered

 a PFIC?

What CFC information needs to be

 disclosed by a partnership to its

 U.S. partners?

What U.S. tax liabilities should

I expect as a result of my

interest in a CFC?

Do you need help with Controlled Foreign Corporation tax planning?
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