International Tax

CFCs — Foreign Personal Holding Company Income (Portfolio 6220)

  • This Portfolio provides a analysis of foreign personal holding company income, foreign base company income and “Subpart F income”.

Description

This Tax Portfolio, CFCs — Foreign Personal Holding Company Income provides a detailed analysis of one of the categories of foreign base company income: foreign personal holding company income, which includes certain dividends, interest, related person factoring income, rents, royalties, income from annuities, commodities transactions, and foreign currency transactions, and certain other income. The other categories of foreign base company income – foreign base company sales income, foreign base company services income, and foreign base company oil related income – are analyzed in detail in related Portfolio 928 T.M., CFCs — Foreign Base Company Income (Other than FPHCI).

Table of Contents

I. Introduction
II. Legislative and Regulatory History
III. Overview
IV. General Rules and Definitions
V. Dividends, Interest, Rents, Royalties, and Annuities
VI. Gains from Certain Property Transactions
VII. Commodities Transactions
VIII. Foreign Currency Gains
IX. Income Equivalent to Interest
X. Income from Notional Principal Contracts
XI. Income from Stock Lending Transactions
XII. Income from Personal Service Contracts
XIII. Special Exceptions
XIV. CFC-Owned Partnerships

Lowell Yoder
Partner
McDermott Will & Emery LLP
Damon-Lyon
Damon Lyon
Partner
McDermott Will & Emery LLP
David-Noren
David Noren
Partner
McDermott Will & Emery LLP
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