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Video instructions and help with filling out and completing Revoke s corp election retroactively
Instructions and Help about Revoke s corp election retroactively
Music this video discusses the tax cuts and Jobs Act repeal of section 958 b4 regarding downward attribution to a u.s. corporation the change was intended to prevent inverted companies from D controlling their controlled foreign corporations for example say that a u.s. parent company USP owns 100% of CFC a controlled foreign corporation USP inverts so that it now has a foreign parent FP we will assume that FP is not a surrogate foreign corporation under Section 78-74 after the inversion USP would like to avoid subpart F income earned by CFC in an attempt to avoid the subpar F income FP invest cash or property into CFC in exchange for newly issued shares in CFC in exchange for the cash or property CFC issues - FP 51% of its shares after the contributions USP now owns 49% of CFC under the old attribution rules CFC would no longer be a controlled foreign corporation under these old rules the shares of CFC owned by FP were not attributed to USP however with the new change in law the 51% of shares in CFC owned by FP will be attributed to USP since USP directly owns 49% of the shares and it constructively owns 51% of the shares CFC will continue to be a controlled foreign corporation as a controlled foreign corporation USP will need to continue to file form 54 71 on an annual basis as a category 5 filer and pick up its proportionate share of any subpart F income Music.