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Section338

Sales of CFCs Got Harder?

December 3, 2018 By Jasper L. (Jack) Cummings, Jr.

Our Federal Tax Group gives a glimpse into the brave new world of selling foreign assets and stock in the wake of the Tax Cuts and Jobs Act.

  • Selling a U.S. sub versus selling a CFC
  • GILTI as a new option over Subpart F
  • Analyzing the options

Read the full advisory here.

Filed Under: Federal Tax Advisory Tagged With: CFC, Controlled Foreign Corporations, GILTI, global intangible low-taxed income, Section338, Subpart F, Tax Cuts and Jobs Act

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