Category: LLCs

Switching From S to C Corporation Taxation?

We have previously discussed LLCs and S Corps –  http://www.mooresrowland.tax/2018/12/the-pros-and-cons-of-llcs.html http://www.mooresrowland.tax/2014/09/irs-partners-share-of-llc-income-is.html http://www.mooresrowland.tax/2019/08/strategies-that-partners-or-llc-members.html We also discussed converting from an LLC to an S corp –  http://www.mooresrowland.tax/2019/03/converting-llc-to-s-corp.html

Investing in the USA

We commonly speak with investors from Asia and elsewhere who are interested in investing the USA.  Most commonly the investment is real estate, but we

Converting an LLC to an S Corp

Many small business owners form limited liability companies (LLCs) rather than corporations because an LLC is flexible and has minimal state reporting requirements.  Many US

GILTI Rules Particularly Onerous for Non-C Corporation CFC Shareholders

Background –  http://www.mooresrowland.tax/2018/02/us-exposed-owner-of-international.html http://www.mooresrowland.tax/2019/01/gilti-regime-guidance-answers-many.html     Summary The recently enacted tax reform legislation significantly expanded the application of Subpart F, including by adding a new