CFCs and the Individual Shareholder

09.14.2020
Tax Notes International
Article

H. David Rosenbloom is a Member with Caplin & Drysdale in Washington, director of the international tax program at New York University School of Law, and a member of Tax Analysts’ board of directors. Jaehong Lee is an attorney with Kim & Chang in Seoul.

The authors are grateful to their colleague Josiah Child for his many insightful comments.

In this article, the authors describe how the subpart F and global intangible low-taxed income rules affect the taxation of income of individual shareholders of controlled foreign corporations.

Copyright 2020 H. David Rosenbloom and Jaehong Lee. All rights reserved.

For the full article, please visit Tax Notes' website (subscription required) or click the PDF link above.

Attorneys

Related Practices/Industries

Jump to Page

We use cookies to make your experience of our website better. By continuing to browse this site you consent to the use of cookies. Please visit our Privacy Policy for more information.