Planning Notes For U.S. Businesses Operating Overseas
- Topics:
- Global Strategy
- Tags:
- CFC,
- Finance,
- Gatti & Associates,
- IBM Lotus Notes,
- Investment,
- Shareholder,
- Stock,
- U.S.
- Source:
- Gatti & Associates
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Overview: U.S. companies do business overseas using many forms and structures, e.g., controlled foreign corporations (CFC's), partnerships, trusts, hybrid entities, etc. A typical form of doing business outside the U.S. is through a corporation that is organized in a foreign country. A CFC is foreign corporation where more than 50% of the total combined voting power of all classes of stock of the corporation entitled to vote or U.S. shareholders own the total value of the stock on any day during the foreign corporation's tax year. To determine whether a U.S. person is a U.S. shareholder under the rules, the U.S. person is considered to own stock when the U.S person owns such stock directly, indirectly through foreign entities or constructively under certain rules that attribute stock ownership from one entity to another. Some of the aspects, which have been studied regarding this, include: taxing U.S. shareholders on CFC profits, reporting foreign ownership, international boycotts, outbound transfers of property, consolidated reporting.
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Format: HTML | Date: Jan 2003 | Pages: 1
