What specific categories of income are considered Subpart F income?
My CFC earns a mix of income — some from selling products, some from licensing IP, some from investing excess cash, and some from providing consulting services to related companies. I need to figure out which of these fall into Subpart F. Can you break down each category of Subpart F income with examples? I especially want to understand foreign personal holding company income since that seems to be the broadest bucket.
Related Questions
What types of payments count as base erosion payments under BEAT?
We're trying to figure out exactly which payments our U.S. company makes to related foreign entities count as 'base erosion payments' for BEAT purposes. We pay our foreign parent for inventory (COGS),...
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 ...
How exactly is the BEAT calculated? Walk me through the minimum tax computation.
I understand BEAT conceptually but I'm struggling with the actual math. My U.S. corporation has $150 million in taxable income, $40 million in base erosion payments that are deductible, and $5 million...
What is the Base Erosion and Anti-Abuse Tax (BEAT) and who does it affect?
Our company is a U.S. subsidiary of a large foreign multinational. Our CFO mentioned we might be subject to something called BEAT — the Base Erosion Anti-Abuse Tax. I looked it up and it seems very co...
How do I calculate FDII for my U.S. corporation that has both domestic and foreign customers?
My U.S. C-corp has $10 million in total revenue — $6 million from foreign customers and $4 million from domestic customers. Our total deductions are $7 million, and we have about $2 million in depreci...
What is the FDII deduction and can my U.S. corporation benefit from it?
I own a U.S. C-corporation that sells software licenses to customers all over the world. About 60% of our revenue comes from foreign customers. Someone mentioned that there's a deduction called FDII t...
How do you calculate GILTI? What are tested income, QBAI, and net DTIR?
I understand GILTI at a high level but I'm struggling with the actual calculation. My CPA mentioned terms like 'tested income,' 'QBAI,' and 'net deemed tangible income return' and I got lost. I own a ...
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...
What does 'trade or business within the United States' mean under IRC 864(b)? My tax advisor says this determines everything.
I'm an Australian freelance developer with a Wyoming LLC. I do all my work remotely from Melbourne but have U.S. clients who pay my LLC. My tax advisor says whether I'm engaged in a 'trade or business...
What exactly is 'effectively connected income' under IRC 864(c)? How do I know if my LLC income qualifies?
I'm a Brazilian business owner with a Florida LLC that sells digital products online. Some sales go to U.S. customers, some to international customers. My CPA says I need to figure out what income is ...
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.
