What is Previously Taxed Income (PTI) and how does IRC 959 work for CFC distributions?
My CFC has been operating for several years and I've been including Subpart F and GILTI income on my U.S. tax return. Now the CFC is about to distribute a large dividend. My understanding is that I shouldn't be taxed again on income I've already paid U.S. tax on. How does the PTI exclusion work under IRC 959? And how do I track which earnings have been previously taxed?
Related Questions
What is Subpart F income and how does it apply to foreign-owned business structures?
I've been reading about Subpart F income in the context of CFC rules and I'm confused about how it fits in with GILTI. I'm a U.S. citizen running a business through a foreign corporation. Some of the ...
What is the Section 962 election and why would an individual CFC shareholder make it?
I'm a U.S. citizen who owns a CFC through a personal holding structure (not through a U.S. corporation). My CPA says I should consider a 'Section 962 election' to reduce my tax on GILTI and Subpart F ...
I'm a Taiwan resident with a U.S. LLC — does Taiwan tax me on undistributed LLC earnings under the new CFC rules?
I'm a Taiwanese tax resident running a U.S. software LLC (single-member, disregarded for U.S. tax). I just learned Taiwan rolled out CFC rules effective 2023 and I'm worried that even if I leave profi...
What is GILTI and how does it affect U.S. shareholders of foreign corporations?
I keep hearing about GILTI in the context of international tax reform. I'm a U.S. person who owns a foreign company, and someone told me I might owe tax on income my foreign company earns even if I ne...
I'm from Turkey — how does my U.S. LLC get taxed?
I'm a Turkish citizen living in Istanbul. I formed a Wyoming LLC for my e-commerce business. I work from Turkey selling to U.S. customers through Amazon. What are my IRS and Turkish GIB (Revenue Admin...
I'm from Canada — how does my U.S. LLC get taxed?
I'm a Canadian citizen and resident in Toronto. I formed a Delaware LLC for my software development freelancing business with U.S. clients. I do all work from Canada. What are my tax obligations in bo...
My CPA said IRC 871 governs how I'm taxed as a nonresident alien — what does this section actually cover?
I'm a Japanese citizen running an online marketing agency through a U.S. LLC. I live in Tokyo and have never set foot in the U.S. My CPA said Section 871 of the IRC is the main section that determines...
I'm from Italy — how does my U.S. LLC get taxed?
I'm an Italian citizen living in Milan. I formed a Delaware LLC for my design consulting business serving international fashion brands. I work entirely from Italy. What are my IRS and Agenzia delle En...
How does Japan tax distributions from my U.S. LLC?
I transfer money from my U.S. LLC bank account to my Japanese personal bank account every month. My Japanese tax advisor says these are dividends from a foreign corporation and should be taxed as divi...
I'm from South Korea — how does my U.S. LLC get taxed?
I am a Korean citizen living in Seoul. I set up a Delaware LLC for my online tutoring platform. I manage everything from Korea. What do I owe the IRS and the National Tax Service (NTS)? I know Korea h...
Have a similar question?
ForeignLLCTax members get expert answers with IRS citations. One CPA consultation costs $200+. Full access is $9.99/month.
Become a Member — $9.99/moDisclaimer: All content on ForeignLLCTax.com is created by a tax professional and is provided for general educational and informational purposes only. It does not constitute tax, legal, or accounting advice, and should not be relied upon as such. Every tax situation is different — for advice specific to your circumstances, please consult a licensed CPA, Enrolled Agent, or tax attorney. By using this website, purchasing a subscription, or accessing any tools or services, you acknowledge that no client-professional relationship is established between you and ForeignLLCTax.com or its operators. This website is not affiliated with the IRS.
