Re: US citizens/residents/corporations and international taxation
in the example i gave above, US shareholders get taxed on part of the income . the entity is referred to as controleld foriegn corporation, and the subpart F income which has a few different components which i dont remember all at the top of my head, include income from rent, royalties, interest, they are taxable. but there are certain exceptions which may have changed since I last dabbled in this, but can look it up. its called the deminimis exception for CFCs and used to be $1M or 5% of gross CFC income.