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The income test is met if 75% or more of the foreign corporation's gross income is passive income, defined as foreign personal holding company income with modifications. The asset test is met if 50% or more of the foreign corporation's average assets (as defined in the IR Code) produce, or could produce passive income, or are assets (such as ...
A corporation is a personal holding company if both of the following requirements are met: [15] Gross income test: at least 60% of the corporation's adjusted ordinary ...
Foreign personal holding company income (FPHCI), including dividends, interest, rents, royalties, and gains from alienation of property that produces or could produce such income. Exceptions apply for dividends and interest from related persons organized in the same country as the CFC, active rents and royalties, rents and royalties from ...
Ways a holding company can be set up include as a C Corporation or a limited liability company (LLC), both of which can protect owners from personal liability. Which structure the holding company ...
Foreign personal holding company income (FPHCI) is defined for U.S. controlled foreign corporation rules [1] and, with modifications, for U.S. foreign tax credit rules. [2] It consists of interest, dividends, rents, royalties, gains on property producing FPHCI, and certain other items. Exceptions are provided for active rents and royalties ...
Holding: Personal jurisdiction for claims regarding a website require application of the Calder test to establish "minimum contacts" as defined by Int'l Shoe. Twentieth Cent. Fox Film Corp. v. iCraveTV, 53 U.S.P.Q.2d 1831 (W.D. Pa. 2000). [19] iCraveTV was a Canadian Internet startup that offered real time streaming of television over the Internet.
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In what is sometimes known as a "domestic reverse hybrid" strategy, a non-US corporation may set up a US holding company which elects to be treated as a corporation for US tax purposes, but which its home country tax law sees as a flow-through entity. The US holding company receives a loan from its home country parent which it invests in a US ...