United States:
Impact Of Tax Reform On The Purchase And Sale Of Controlled Foreign Corporations — Selected Considerations
20 September 2018
Fenwick
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The application of §1248 and §338(g) in the context of
the purchase or sale of a controlled foreign corporation (CFC) has
long been one of the most complex areas of the tax code. The
recently enacted tax reform act — herein, the ''2017
tax act'' or the ''Act''2 — has
overturned the settled principles that applied to the purchase and
sale of CFC stock. Read this article for a brief overview of the new
rules on purchases and sales of CFC stock in light of the new rules
and considerations applicable to tax reform.
Originally published in Tax Management International
Journal, Vol. 47, No. 9, p. 559, 09/14/18
The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.
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