Internal structure in CFCs If you're a U.S. person who owns (or has a stake in) a company incorporated outside the United States, three terms should be on your radar: Controlled Foreign Corporation (CFC), Subpart F income, and GILTI. These rules exist to prevent U.S. shareholders from parking profits offshore indefinitely — and they can generate a current U.S. tax bill even if you never see a dividend from the foreign company. This week, we're breaking down how these three pi

If you live or work abroad, there's a good chance you have a foreign retirement account — and the U.S. has its own rules for it that don't always match your host country's. From employer contributions being taxed before you retire, to reporting requirements that exist even when you owe zero tax, the gaps between systems catch a lot of expats off guard. Here's what you need to know.