How to Avoid the Tax Pitfalls of 26 U.S.C. §956 when Negotiating Lending Transactions for Clients with Foreign Country Operations
A popular conduit for operating in a foreign country is a controlled foreign corporation (CFC). In 2012, U.S.-controlled foreign corporation earnings topped $793 billion as the world economy became increasingly interconnected. See, IRS, Statistics of Income. How does the aforementioned trend impact the legal profession?










