You are most welcome. Please subscribe and share. If you want to access more resources, check my website: ✔farhatlectures.com/ ✔Instagram: @farhatlectures ✔ Linkedin: www.linkedin.com/in/professorfarhat/ ✔Facebook:@accountinglectures ✔Twitter: @farhatlectures 🎤Email: Mansour.farhat@gmail.com
Thank you for your great lecture! By the way, if a shareholder owns exactly 50% stock, but no more, in a foreign corporation, would it be called CFC? Or he/she must own at least 50.1% or 51% or more of a foreign corp to have a CFC?
Are foreign subsidiaries incorporated in America but just do business in foreign countries or are they incorporated in and do business foreign lands but are controlled by domestic shareholders??? Because if the latter is true why would it matter if the sub was a FCF or not? If it wasn’t, than the distributions to American owners would be subject to the DRDs and only individuals would be taxed so its only double taxation. Thanks
It’s the latter, and the point is the timing of tax collection not double taxation issues. If a US company earns money via a CFC but perpetually reinvests their earnings overseas/uses it for other purposes the US will never get to tax it (without Subpart F/GILTI inclusions etc).
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Best explanation!!!! 😊
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The best explanation of SubparF hands down. I hope you have an episode about GILTI . Thank you sir!
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Thank you so much professor ❤️
Excellent explanation! Thx!
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Thank you for posting this video.
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Great information, thank you so much!
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Great explanation, thank you so much
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Awesome!
If a US corp. sells to it's ireland subsidiary, how is that income not included on it's 1120? Because it's considered intercompany?
Thank you for your great lecture! By the way, if a shareholder owns exactly 50% stock, but no more, in a foreign corporation, would it be called CFC? Or he/she must own at least 50.1% or 51% or more of a foreign corp to have a CFC?
Antonmursid🙏🙏🙏🙏🙏✌👌💝🇮🇩🇮🇩🇮🇩🇮🇩🇮🇩✌👌💝
Are foreign subsidiaries incorporated in America but just do business in foreign countries or are they incorporated in and do business foreign lands but are controlled by domestic shareholders??? Because if the latter is true why would it matter if the sub was a FCF or not? If it wasn’t, than the distributions to American owners would be subject to the DRDs and only individuals would be taxed so its only double taxation. Thanks
It’s the latter, and the point is the timing of tax collection not double taxation issues. If a US company earns money via a CFC but perpetually reinvests their earnings overseas/uses it for other purposes the US will never get to tax it (without Subpart F/GILTI inclusions etc).
It's 10 percent or more NOT more than ten percent. There is a difference.
so confusing......