Lowell Yoder wrote this bylined article describing controlled foreign corporation (CFC) sale of foreign business to a related CFC in a taxable transaction. “As a general rule, gain on the sale of property used in the CFC’s business should not be FPHCI (foreign personal holding company income) but gain with respect to passive assets can be FPHCI, and under limited circumstances gain that is not FPHCI can be foreign base company sales income,” Mr. Yoder wrote.