Citizen of foreign country who meets either the green card test or the substantial presence test
What is a resident alien individual?
100
A relevant issue for US companies with operations in low tax jurisdictions.
What is transfer pricing?
100
Any foreign corporation if US persons own more than 50% of the corporation's stock taking into account only those US persons that own at least 10% of the stock.
What is a controlled foreign corporation (CFC)?
100
A foreign entity with multiple members if at least one member does not have limited liability.
What is a partnership?
100
Originated in 1960 when 18 European countries plus US and Canada joined forces.
What is the organization for Economic Cooperative and Development (OECD)?
200
Unilateral solutions to the international solutions to the international problems by individual countries
What are territorial and credit systems?
200
Controlled entities generally must charge each other an arm's length rate of interest.
What are loans and advances?
200
The US generally taxes the 10% shareholders of a CFC on their pro-rata shares of certain income of the CFC without regard to whether the income is distributed to the shareholders.
What are Subchapter F rules?
200
A foreign entity with multiple entities if all members have limited liability.
What is a corporation?
200
Governments are facing budget shortfalls and public voices are questioning whether multi national companies are paying their fair share of taxes.
What is the purpose of BEPS (the OECD's action plan on Base Erosion and Profit shifting?
300
Corporations created or organized under the laws of 50 states or District of Columbia?
What is a domestic corporation?
300
The comparable uncontrolled transaction method, the comparable profits method, and the profit split method.
What are the 3 specified methods for estimating an arm's length charge for transfers?
300
If 75% or more of the corporation's gross income for the taxable year is passive income or the average market value of the corporation's passive assets is 50% or more of the corporation's total assets.
What is a passive foreign investment company?
300
Entities that are treated as flow-through or disregarded for US tax purposes but as corporations for foreign tax purposes.
What is a "hybrid entity"?
300
New reporting requirement for larger companies will make detailed country by country tax and financial information visible to many eyes, and possibly not just of tax authorities.
What is the most surprising takeaway from the BEPS project?
400
The US does not tax foreign source income earned by a US person through a foreign corporation until those profits are repatriated.
What is the deferral privilege?
400
Applies if the transfer price used by the taxpayer is 200% or more (or 50% or less) of the amount determined under IRC Section 482.
What is the transactional penalty?
400
Shareholders who can obtain the necessary information can elect to be taxed currently on their pro rata share of the PFIC 's earnings and profits.
What is a qualified electing fund method?
400
Entities that are treated as corporations by the US but as flow through by foreign country.
What is a "reverse hybrid entity"?
400
Transaction flows, tax incentives and taxing the supply chain.
What are some of the tax considerations for activities that may change?
500
Fairness, the need to collect tax revenues, economic neutrality and enforcement constraints.
What are the tax policy objectives of the Current US jurisdictional system?
500
The rate if the transfer price used by the taxpayer is 400% or more or if the adjustment to taxable income exceeds the lesser of $20 million or 20% of the taxpayer's gross receipts.
What is 40%?
500
The result when a US shareholder of a PFIC makes a mark to market election for marketable PFIC stock and there is an excess of the fair market value of the PFIC over the shareholders adjusted basis in the stock.
What is income?
500
Foreign losses are allowed to flow through and be deducted by the US parent.
What is one of the tax advantages of hybrid entities?
500
It is meant to capture the tax revenue for goods and services consumed by UK based customers.
What is the Diverted Profits tax, or "Google Tax" by the UK press?