The 2017 Tax Act significantly increased the benefits of a section 338(g) election for a domestic corporate purchaser of stock in a controlled foreign corporation (CFC). If an election is made, the Buyer is treated as...more
Following the 2017 Tax Act, a domestic corporate purchaser of stock in a controlled foreign corporation (CFC) generally will desire to make a section 338(g) election. A section 338(g) election provides a stepped-up basis in...more
Following the 2017 Tax Act, the US tax costs to a corporate US shareholder that sells stock in a controlled foreign corporation (CFC) are significantly reduced. Beginning in 2018, the amount of gain will be generally less...more
The 2017 tax act added two new separate foreign tax credit limitation categories, or baskets. Under current law, there are now baskets for income attributable to a foreign branch (the foreign branch basket) and for amounts...more
The purpose of section 367(b) in the context of an inbound section 332 liquidation or section 368 reorganization (inbound asset transfer) is to ensure that the domestic acquiring corporation (or domestic shareholder of the...more
Changes made by tax reform have caused companies to reevaluate their structures. This reevaluation extends to the most fundamental decision: choice of entity. The choice of entity decision now frequently hinges on two key,...more