CFCs are generally painful for U.S. tax purposes. In this session, we explore the rules for reorganizing or eliminating CFCs in order to reduce tax costs and compliance burdens. Topics include tax-free reorganizations and creative use of the check-the-box rules to make things less bad.
Learning Objectives
• Identify options for restructuring and reorganizing to reduce filing burdens
• Determine whether an entity can make use of a reorganization
Major Topics
• Form 5471
• Controlled foreign corporation
• Entity structuring
• Entity liquidation
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