Liquidating distribution foreign corporation

19-Jul-2017 08:14

For most tax practitioners, this would elicit the following Pavolovian reaction: “You should NEVER put real estate inside a corporation.” And while there are very few NEVERS in the tax world, this one is pretty darn accurate.

But do you really understand why you should never put real estate into a corporation?

A CFC is defined as a foreign corporation that is owned more than 50 percent by one or more US shareholders.

Effectively, the dividend equivalent amount is the effectively connected earnings and profits plus the decrease in US equity. The following types of interest are exempt from the branch profits tax: The foreign corporation may be able to reduce the 30% rate under applicable treaty provisions.

Double taxation is the hallmark of the subchapter C regime.

Unique in the tax world, C corporations are first taxed on their income at the entity level.

C corporations, like flying, were once a choice of last resort.

liquidating distribution foreign corporation-88

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The aversion of most taxpayers to doing business as a C corporation was attributable to the possibility of suffering a fate worse than death: DOUBLE TAXATION.

Normally, an LLC-to-corporation conversion is tax-free if the prior business owners are in control of 80% or more of the stock of the new corporation ).

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