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FPHC |
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Lookthrough treatment of payments between related CFCs under FPHC income rules: The TIPRA adds a new temporary exception from subpart F for dividends, interest, rents and royalties received by one CFC from a related CFC, to the extent attributable to the payer's non-subpart F income. If enacted, this would end the deferral of subpart F income that currently arises if a CFC or FPHC has a taxable year ending after that of its U. shareholders of foreign corporations can be subject to tax under the CFC and PFIC anti-deferral provisions; the FPHC provisions have been repealed. |
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