Subpart F: Taxation of Foreign Income Earned by U.S.-Controlled Foreign Corporations

In 2012, Google made headlines when it was revealed that the multinational company had avoided approximately $2 billion in worldwide income taxes the previous year by funneling the equivalent of 80% of the company's pre-tax profit through a Bermuda shell company. The tax avoidance techniques used by the company (the...

Crackdown on Tax Treaty Abuses

Tax authorities throughout the world are cracking down on taxpayers – individuals and corporations – that utilize some aggressive tax planning strategies. While most of these schemes are perfectly legal and merely take advantage of loopholes in the international tax system, there is a growing concern that they not only...

Corporate Inversion – Assertive Tax Planning & Political Concerns

Our recent article published, The Corporate Inversion: From Obscure Strategy to Hot Trend addresses why many businesses and longstanding American icons have made the move towards corporate inversion, a tax reduction method of re-incorporating a company in another country if a significant portion of the company's income is derived from...