Legal

This article analyzes a U.S. company's inability to utilize the APB 23 exception on a portion of the outside basis of a subsidiary as a result of the provisions of Subpart F of the U.S. Tax Code. 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.

Posted on Wed, 30 Jan 2008 10:05:11 -0600 at http://ezinearticles.com/?APB23-Implicat...;id=956561