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Impact of Tax Reform on the Purchase and Sale of Controlled Foreign Corporations — Selected Considerations

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.​​


Reproduced with permission from Tax Management International Journal, Vol. 47, No. 9, p. 559, 09/14/2018. Copyright © 2018 by The Bureau of National Affairs, Inc. (800-372-1033) http://www.bna.com.