Under the U.S. tax law, there exist a number of anti-deferral rules that apply to offshore companies and need to be taken into consideration when planning and managing your offshore operations. Under the Subpart F rules, if your company is a controlled foreign corporation (CFC), then you need to understand whether the income earned is through active business operations (and generally not taxed until it is repatriated) or from passive operations (and generally subject to current inclusion in income as Subpart F income). Other anti-deferral rules exist for passive foreign investment companies (PFICs) and other entities.
The Law Office of Deborah J. Jacobs has significant experience in deferral planning. We can help you understand the risks and benefits associated with deferral of income and to identify situations in which the deferral of income is desirable and other situations in which deferral is not always the most tax efficient choice.
We look forward to working with you to resolve your international tax matters. |
The Law Office of Deborah J. Jacobs, located in New York City, represents clients worldwide on international tax matters under the tax laws of the United States. Our practices areas consist of International Tax Compliance (including, but not limited to, Offshore Voluntary Disclosure Programs, Streamlined Offshore Compliance Procedures ((both Domestic and Foreign)), Dual Citizenships, FBAR Compliance and FATCA Compliance) and International Tax Planning (including, but not limited to, Cross-Border Transactions, Tax Treaty Planning, Foreign Tax Credit Planning, Repatriation Planning and Deferral Planning). Our clients are individuals, foreign companies and entities, and financial institutions doing business or residing in the United States, or individuals, U.S. companies and entities, and financial institutions doing business or residing abroad. We look forward to working with you to resolve your international tax matters. Attorney Advertising.