Forbes contributors publish independent expert analyses and insights. Head of McDermott Will & Emery’s U.S. & International Tax practice. Gain on the sale of stock in a foreign subsidiary generally is ...

One goal of the Tax Cuts and Jobs Act (TCJA) was to end the lockout effect and encourage U.S. companies to bring back cash held by foreign subsidiaries. It also sought to make the U.S. more tax ...

Learn about Controlled Foreign Corporations (CFCs), their structure, tax implications, and how U.S. tax laws affect their ...

Yesterday's post parsed the definition of "subsidiary" in Corporations Code Section 189. Because a subsidiary must be a corporation as defined in Section 162, a subsidiary cannot be a foreign ...

In today’s economic environment, lenders often seek to maximize the amount of collateral supporting a borrower’s loan. But a borrower needs to be aware that securitizing a loan with assets or stock of ...

The formation of a subsidiary under the laws of a foreign country may not seem to implicate the California Corporate Securities Law. Yet, an offer and sale may occur “in this state” within the meaning ...

The draft Tax Cuts and Jobs Act, H.R. 1, released by the House Ways and Means Committee last week, makes many important changes to the tax treatment of U.S. corporations that own foreign corporations.

Parent companies create subsidiary corporations and maintain them as separate legal entities, although they still retain an element of control through partial or total shareholding and the ability to ...

We collaborate with the world's leading lawyers to deliver news tailored for you. Sign Up for any (or all) of our 25+ Newsletters. Some states have laws and ethical rules regarding solicitation and ...

The article explains how Section 80M applies only to domestic dividends, leaving foreign subsidiary dividends fully taxable in India. This creates economic double taxation for Indian parent ...