U.S. Inbound or Foreign-to-Foreign Transfers

Summary

This practice note discusses the inbound side of corporate reorganizations. That label—"inbound"—is given to corporate reorganizations where property or securities are moved from a foreign jurisdiction to a U.S. jurisdiction. The major focus of the regulations dealing with inbound (as well as movement from one foreign country to another—"foreign-to-foreign") is on taxation of U.S. persons holding shares of a controlled foreign corporation (CFC).