Intercompany Receivable Results in Section 956 Inclusion for U.S. Corp.

The Subpart F rules can result in foreign profits being subject to tax in the U.S.  In the recent Crestek v. Commissioner, 49 T.C. 5 (2017), the court addresses unpaid advances a controlled foreign corporation made to its U.S. parent.  The case ….. The post Intercompany Receivable Results in Section 956 Inclusion for U.S. Corp. appeared first on Houston Tax Attorney.
Source: Houston Tax Attorney

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