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,...more
9/18/2018
/ Asset Management ,
C-Corporation ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Federal Taxes ,
GILTI tax ,
Income Taxes ,
International Tax Issues ,
IRS ,
New Rules ,
Partnerships ,
Pass-Through Entities ,
Private Equity Firms ,
Shareholders ,
Stock Purchase Agreement ,
Stock Sale Agreements ,
Stocks ,
Tax Code ,
Tax Cuts and Jobs Act ,
Tax Deferral ,
Tax Planning ,
Tax Reform