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.
Recent Developments in the Section 956 Deemed Dividend Rules<br></font>
<i><b>How to Avoid the Tax Pitfalls of 26 U.S.C. §956 when Negotiating Lending Transactions for Clients with Foreign Country Operations</i></b><p>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?
By
Marcus Dyer
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