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How to Repatriate Earnings Tax-Free

Three pieces of IRS guidance issued over the past year provide a roadmap for corporate taxpayers.

November 2, 2009

In the realm of overseas investment earnings, the Internal Revenue Code — specifically Section 956(c) — defines "U.S. property" to include an obligation of a "related U.S. person" held by a controlled foreign corporation (CFC). In general, an investment in U.S. property by a CFC produces dividend income for the CFC's U.S. shareholders in an amount equal to the amount of the investment.¹ Read more...

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