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 exchange of stock of a foreign corporation by a United States person will be included in income as a dividend if the foreign corporation was a CFC at any time during the prior 5-year period and the US person was a...