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)