id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
ftr-403	Lokken, Lawrence	Whatever Happened To Subpart F? U.S. CFC Legislation after the Check-the-Box Regulations	2022	26	.pdf	application/pdf	11144	478	54	Lawyer 375 (1992) business entity organized under the laws of or resident in a foreign country is thus, for U.S. income tax purposes, either a corporation or a partnership. Because IPCo is subject to no tax in its home country, the net effect of the royalty payments is to reduce income tax on an amount equal to the royalties from 35% (the additional country L tax OPCo would pay if it had no deduction for royalty expense) to 10% (the country L withholding tax on the royalties).	cache/ftr-403.pdf	txt/ftr-403.txt