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