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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
Prior to the passage of the Tax Cuts and Jobs Act (the “Act”), one of the more controversial and hotly-debated tax benefits was the so-called “carried interest,” which allowed certain fund managers and venture capital firms...more