Subpart F Rules on Taxation of Controlled Foreign Corporations

Navigating the Complexities in Tax Planning for Multinational Companies

Recording of a 90-minute CPE/CLE webinar with Q&A

Conducted on Tuesday, March 9, 2010

Recorded event now available

or call 1-800-926-7926
Course Materials

This CLE course will prepare counsel and advisors to multi-national companies to meet the requirements of the current Subpart F rules governing the taxation of controlled foreign corporations. The panel will review recent enforcement developments and discuss key tax planning strategies.


Subpart F governs the taxation of income generated by controlled foreign corporations (CFCs). Certain non-U.S. earnings are deemed distributed under the complex Subpart F rules such as passive income and income from certain sales of goods or services.

Several new developments in the Subpart F rules warrant attention of tax counsel and advisors, including guidance allowing CFCs to improve liquidity without increasing the amount of "U.S. property."

The Obama administration has made international tax reform a critical element of proposed tax reform initiatives as the government seeks to close perceived tax loopholes in an effort to raise much-needed revenue. As a result, multinational companies can expect to see more rigorous IRS enforcement.

Listen as our authoritative panel of tax attorneys discusses Subpart F rules for multinational companies, recent legal and enforcement developments, and tax planning strategies.



  1. Determination of a controlled foreign corporation (CFC)
    1. What is a CFC?
    2. Control tests
    3. Attribution rules
  2. Tax treatment of CFC income
    1. In general
    2. Subpart F income
    3. Exceptions and limitations
  3. Special issues and legal developments
    1. Investments in U.S. property
    2. Treatment of previously taxed income
    3. Subpart F Income partnership blocker transactions
    4. Legislative reform


The panel will review these and other key questions:

  • What is the effect of voting agreements on CFC determination?
  • How can CFCs take advantage of recent guidelines allowing CFCs to improve liquidity without increasing the amount of U.S. property under section 956?
  • What tax reform initiatives and enforcement trends can multinational companies expect to see in the near future?


Daniel L. Gottfried
Daniel L. Gottfried

Rogin Nassau

His practice encompasses domestic and international business transactions, as well as federal, state, and international...  |  Read More

Jeff Rubinger
Jeff Rubinger

Holland & Knight

He practices focuses on domestic and international taxation. He has experience in a broad range of transactions...  |  Read More

Michael J. Miller
Michael J. Miller

Roberts & Holland

Mr. Miller has provided U.S. tax advice to domestic and international clients for more than 15 years. Working with...  |  Read More

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Strafford will process CLE credit for one person on each recording. CPE credit is not available on recordings. All formats include course handouts.

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