OrbitaxProposed regulations issued for determination of earnings and profits attributable to stock of CFCs under IRC Sec. 1248
|Proposed Changes|United States
The US Treasury Department and the Internal Revenue Service (IRS) have issued proposed regulations for the determination of earnings and profits (E&P) attributable to stock of US controlled foreign corporations (CFCs).
The regulations were issued under Section 1248 of the US Internal Revenue Code, which requires that all or a portion of the gain recognized on the sale or…
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