APB23 Implications For Corporations With Subpart F Income
Topics: APB23, subpart F, douglas Stransky, international tax
If your company intends to indefinitely reinvest all of your CFC’s accumulated unremitted earnings, can your company utilize the APB 23 exception to not record deferred taxes on the portion of your CFC’s unremitted earnings that relate to your CFC’s investment in another 30% owned foreign subsidiary.
Facts:
Company […]