Sure, I can address tax issues here. I am assuming we are dealing with a foreign corporation formed in 2023 or later. And, I am assuming a US person [individual or domestic corporation (u201cDCu201d)]d owns the shares of the foreign corporation. So, we are dealing with a so called controlled foreign corporation (u201cCFCu201d) here (Section 957(a)).As a FC formed prior to 2023. may have to consider the one time transition tax u2023 where Treasury taxes the CFC on its undistributed earnings and profits as detailed in Section 965.A CFC shareholder I.e. the US person may pay tax on some of the CFCu2019s earnings directly. This event happens when the CFC has so called Subpart F income which represents different classes of income earned by the CFC under Section 954(a). Examples of this type of income earned by the CFC include items like dividends, interest income, rents, or royalties. Another item include sales income between related parties in certain cases though not all. Another important item comes from services income where the CFC shareholder controls the full outcome of certain types of personal services provided by the US shareholder directly or indirectly through the CFC under Section 954(e).However, some CFCu2019s do not face the above paragraph though the CFC now deals with a new provision under Subpart F as part of new Section 951A. If the CFC (owned by a DC) does not pay tax on its taxable income in the foreign country at least at 13.125% tax rate,The DC shareholder will include CFC income on its own tax return and pay additional tax in order to get to this rate above.Note: I have greatly simplified this new tax law provision as means for enhancing viewer readability. As the CFC may take a deduction as an example for a 10% return on its adjusted cost asset base (Section 951A(b)(2)(A). And, the reason for the lower rate centers on Treasury allows the DC shareholder a 50% deduction when including this CFC taxable income in the return (Section 250(a)(1)(B). This fact reduces the tax rate from 21% for domestic corporation to 10.5%. However, the DC may only use 80% of the foreign taxes paid in the home country as an offset against US taxes so this then pushes the rate to 13.125% (Section 960(d)(1)).If the CFC is owned by a US individual tax person, the individual does not get this 50% deduction and thus pays at a much higher US rate for the CFC income coming into his/her individual tax return. So, tax structure planning really helps here.In addition a DC or individual with a CFC has annual Treasury information reporting under Section 6038A. I file this key information report with the other tax documents or as stand alone document depending on the fact situation. Failure to file this report or incomplete or inaccurate filing results in a $25,000 fine under subsection (d).As a final note a CFC owned by a DC, may dividend back its profits (cash) to the DC and the DC does not pay tax on the dividend it receives under Section 245A(a) for the foreign source portion of the dividend (the portion earned from the foreign operations). This provision does not apply for the individual shareholder(s) of the foreign corporation.I have completed the above tax analysis based on a general fact situation. As the situation changes, the tax results may change considerably. www.rst.tax