Subpart F Income
International Tax and IRS Voluntary Disclosure Attorneys in Boston
When a U.S. company does business with a related foreign company, the U.S. business may have additional tax liabilities in the United States as a result of Subpart F income. Subpart F is a part of the Internal Revenue Code that requires U.S. taxpayers to recognize for U.S. tax purposes certain types of income earned by a related foreign business.
When the IRS audits a taxpayer with international investments and business interests, Subpart F is almost certainly raised as an issue. Whether or not a U.S. taxpayer is subject to Subpart F income depends upon an analysis of several interrelated factors. The attorneys at Thorn Law Group understand the Subpart F rules and can advise you of your tax exposure from this area of the tax law, as well as represent you in this complex issue before the IRS.