Subpart F Income Part 1 - Overview

This video provides a high-level understanding of the Subpart F Income provisions under IRC Section 951. Some historical context is given to frame up the purpose of the legislation. The various types of gross income including 3 categories of Foreign Base Company Income are defined and illustrative examples are provided to better convey the rules. This is a first in a series that will dive deeper into the exceptions to the various gross income categories, expense allocation, and subpart F mechanics that are used to determine final inclusions into the US tax base.