The U.S. has a series of anti-deferral rules that apply to U.S. owners of controlled foreign corporations (CFCs), passive foreign investment companies (PFICs) and other types of entities that require U.S. owners to include certain types of income (e.g., Subpart F income) of foreign companies in their U.S. taxable income on an annual basis, regardless of whether such income is repatriated to the U.S. owners as dividends.
We can assist you with identifying risks associated with these anti-deferral rules, and structuring your operations to avoid or minimize current income inclusions. Deferral planning is one of the most important strategies utilized by U.S. multinationals to reduce their effective tax rate for financial statement purposes.