OrbitaxFinal regulations issued for determination of earnings and profits attributable to stock of CFCs
|Approved Changes|United States
The US Treasury Department and Internal Revenue Service (IRS) have issued final regulations for determining the earnings and profits (E&P) attributable to stock of controlled foreign corporations (CFCs) under Section 1248 of the US Internal Revenue Code.
Section 1248 requires that all or a portion of the gain recognized on the sale or exchange of stock of a CF…
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