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Law Firm Financials Law Firm Management Tax

Recent Developments in the Section 956 Deemed Dividend Rules

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?

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As companies seek to capitalize on today’s rapidly globalizing economy, they often look into doing business in foreign countries. Even the largest and most firmly established U.S. corporations, such as Apple, Microsoft and Pfizer, have recently expanded their footprints offshore. See, “Apple, Microsoft and Eight Other Corporations Each Increased Their Offshore Profit Holdings by $5 Billion or More in 2012: 92 Fortune 500 Corporations Boosted Their Offshore Stash by Over $500 Million Each,” Citizens for Tax Justice (March 11, 2013). 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.

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