Month: April 2020

Grantor Trust

Generally speaking, an arrangement will be treated as a “trust” (as opposed to some other type of entity) under the Internal Revenue Code (IRC), if

Subpart F Income from CFC subsidiaries

I have previously discussed subpart F – http://www.mooresrowland.tax/2018/02/us-exposed-owner-of-international.html http://www.mooresrowland.tax/2020/02/the-tax-cuts-and-jobs-acts-impact-on.html Consider first a fact pattern where a U.S. parent owns CFC1, which sells the stock of