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Gavin Werbeloff@travelbuddha.bsky.social |
I think anyone who's trying to extrapalate out from this case is really missing the fact that it's really niche. The entity involved is a Controlled Foreign Corporation, which are their own unique breed of corporations that are not American, but the US Gov't treates as American for tax purposes
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Richard J
@preachypreach.bsky.social
[ View ] |
Yes and no, the circumstances are niche (which is a flaw of the US tax system’s Sub-part F rules being too mechanistic compared to most other similar countries Iyam) but the argument was clearly that you can’t impute the profits of one entity to another person’s tax base, which is much broader…
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