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Stock Sale Gives Rise To Foreign Personal Holding Company Income
September 4, 2026
CM was a third-tier wholly owned Malaysian manufacturing subsidiary of CUS. CM sold its operating assets to RR in exchange principally for RR stock. At the time the sale was ne...

"Robert Willens LLC is neither a registered investment advisor nor a broker/dealer. Subscribers and/or readers are advised that the information contained in The Willens Report is not to be construed or relied upon as investment, tax planning, accounting and/or legal advice, nor is it to be construed in any way as a recommendation to buy, hold or sell (short or otherwise) any security or any other form of investment. All opinions, analyses and information contained herein is based upon sources believed to be reliable and is written in good faith, but no representation or warranty of any kind, express or implied, is made herein concerning any investment, tax, accounting and/or legal matter or the accuracy, completeness, correctness, timeliness and/or appropriateness of any of the information contained herein. Subscribers and/or readers are further advised that the Company does not necessarily update the information and/or opinions set forth in this and/or any subsequent edition of The Willens Report or any version thereof. Readers are urged to consult with their own independent professional advisors with respect to any matter analyzed herein. All information contained herein and/or this website should be independently verified."

 

Recent Reports

Alternative Remedies Warranted Dismissal Of APA Suit
September 4, 2026
Z was born in China. Z moved to the U.S. to attend graduate school. Z's family in China gifted her more than $100,000 in both 2017 and 2018. &...
Single Member LLC Was "The Taxpayer"
September 4, 2026
FS is a limited liability company...that was organized by M, its sole member. FS owns a condominium in a building in Boston. M est...
Taxpayer Successfully Abandoned Alabama Domicile
September 4, 2026
The Revenue Department contended that TP was domiciled in Alabama during the 2019 tax year and was therefore subject to individual income tax in Alabama....
The Net Investment Income Tax Cannot Be Sheltered By FTCs
September 3, 2026
The Cs are U.S. citizens who lived in Paris, France, during the 2015 tax year. That year, the Cs sold shares of stock they held in a French company and realized a profit on the...