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International Tax Blog - New and Interesting International Tax Issues

Eaton Corp. v. Commr., 152 T.C. No. 2 (2019)


Earlier this week the Tax Court concluded that the earnings and profits (E&P) of certain upper-tier CFCs was increased by the amount of Subpart F Income inclusions and Code §956 inclusions (Code §951(a) inclusions) that flowed up from lower-tier CFCs through a U.S. partnership.  Below is a chart of the entity structure in the Eaton case.


Tags: 701 Partnerships, 951 Subpart F Income, 956 Investments in U.S. Property, Charts - Situational Charts