• New Regulations on Partnerships Affect Tax Planning for Foreign Subsidiaries
  • July 1, 2003 | Author: Lewis J. Greenwald
  • Law Firm: Sullivan & Worcester LLP - Boston Office
  • Under the Internal Revenue Code provisions of subpart F, certain undistributed income (passive income and active income earned outside the country of incorporation) is currently taxable to U.S. persons who own 10% or more of the voting stock ("U.S. Shareholders") in a controlled foreign corporation ("CFC"). On July 23, 2002, final regulations were issued to provide guidance on the treatment under subpart F of income earned by a controlled foreign corporation through a partnership.