Bank finance articles and tips

Subpart F rules limit deferral of foreign income by owners of foreign corporations. Earnings of a foreign corporation owned by U.S. taxpayer(s) are generally not taxable in the U.S. until remitted. This general rule is subject to several anti-deferral regimes, including Subpart F. U.S. shareholders (generally U.S. persons owning 10% or more of the vote) of a controlled foreign corporation (CFC) must include in their income currently certain types of income earned by the CFC, under the provisions of Subpart F. These inclusions are accompanied by a deemed-paid credit for corporate shareholders that operates identically to the deemed-paid credit for dividends. A Subpart F inclusion, however, is not a qualified dividend eligible for the reduced 15% tax rate.

The Obama Administration has gone to extraordinary measures to try and prop up the US housing market and the US economy. Time and money are short these days, and the director of the Federal Housing Finance Agency Edward Demarco has virtually eliminated the possibility of passing the buck to the taxpayer.

This spells doom and gloom for a Presidential Administration that has, since 2008, poured billions of dollars into a beleaguered economy and housing industry. Federal housing programs designed to help troubled borrowers amend their current mortgages have only caused banks to drag their feet. In effect, there seems to be no systemic approach that can effectively restructure the US housing market and meet the demands of all the players involved-regulators, banks, borrowers, and taxpayers.