section 964 e - EAS
The Importance of Determining Accurate Earnings …
https://sftaxcounsel.com/the-importance-of-determining-accurate...Section 964 and the accompanying regulations dictate the procedures for foreign corporations to calculate E&P. Section 964(a) states that foreign corporation’s E&P is determined in substantially the same manner as domestic corporation’s …
A Section 245A Dividends Received Deduction Tax Overview
https://www.goldinglawyers.com/section-245a-dividends-received-deduction-overviewDeemed Dividends Under IRC Section 964 IRC Section 964(e) treats as dividends some gains on sales or exchanges of foreign corporation stock by a CFC. § If a CFC sells or exchanges stock of a lower-tier CFC and the selling CFC held the stock …
Offshore Accumulated Earnings | SF Tax Counsel
https://sftaxcounsel.com/the-taxation-of-offshore-accumulated-earnings...Section 959(e) PTEP 15. Section 964(e)(4) PTEP; and 16. Section 951(a)(1)9(A) PTEP Section 3.01 of the Notice also specifies that future regulations will follow the following: Once PTEP is assigned to a PTEP group within an annual PTEP …
Domestic Corporations Can Exempt Foreign Profits from US Tax
https://www.castroandco.com/blog/2020/february/domestic-corporations-can-exempt...2020年2月7日 · Gains on the sale of lower-tier controlled foreign corporations treated as dividends under IRC Section 964(e) DRD-eligible dividends indirectly received through a partnership Section 245A explicitly grants the U.S. Treasury Secretary the authority to prescribe regulations to carry out the provisions of this section.
Electronic Code of Federal Regulations e-CFR - 24 CFR §964 …
https://ecfr.io/Title-24/Part-9641994年8月24日 · 24:4.1.3.1.13.1 SUBPART A Subpart A - General Provisions 24:4.1.3.1.13.1.5.1 SECTION 964.1 964.1 Purpose. 24:4.1.3.1.13.1.5.2 SECTION 964.3 964.3 Applicability and ...
International Tax Considerations Relating to Repatriation in Light …
https://www.bdo.com/insights/tax/international-tax-considerations-relating-to...2020年4月13日 · Volatility created by the novel coronavirus, or COVID-19, pandemic has had an immediate impact on many U.S. taxpayers conducting business abroad. Due to liquidity and cash flow needs, such U.S. taxpayers may need to repatriate cash from their foreign operations. This alert discusses some key international tax issues that taxpayers may need to consider when …
Guidance on Previously Taxed Earnings and Profits | BDO | BDO
https://www.bdo.com/insights/tax/treasury-issues-guidance-on-previously-taxed-earnings...General Rules. The term PTEP refers to earnings and profits (E&P) of a foreign corporation attributable to amounts which are, or have been, included in the gross income of a U.S. shareholder (as defined under Section 951 (b)) under Section 951 (a) or under Section 1248 (a). [1] Under Section 959 (a) (1), distributions of PTEP are excluded from ...
New York State Bar Association Tax Section Report on Section …
https://nysba.org/Sections/Tax/Tax_Section_Reports/Tax_Reports_2018/... · PDF 檔案dividends that arise under Section 1248(a) and Section 964(e). 6. Guidance should provide that Section 245A applies to a foreign corporation that receives a dividend from another foreign corporation, subject to certain exceptions, including for distributions
Tax - KPMG report: Initial impressions of Notice 2019-01 and
https://tax.kpmg.us/taxnewsflash/taxnewsflash-us/tnf-kpmg-report-initial-impressions...The IRS on December 14, 2018, released an advance version of Notice 2019-01 that provides guidance on the treatment of “previously taxed earnings and profits” or PTEP (colloquially referred to as PTI). Notice 2019-01 [PDF 85 KB] announces that Treasury and the IRS intend to issue proposed regulations under sections 959 and 961 that will ...
Section 245A Overview And Requirements: Tax Efficient Repatriation Of A Foreign Subsidiary’s Earnings | TaxConnections Section …
https://www.taxconnections.com/taxblog/section-245a-overview-and-requirements-tax...In the case of deemed dividends under section 964(e)(4) and section 1248, the holding period rules in those sections apply. It is important to note that except in the case of certain deemed dividends that are eligible for the Section 245A DRD, the domestic corporate shareholder must directly hold the SFC stock to satisfy the holding period and be eligible for the Section 245A DRD.
