Subpart F: Sale of a Lower-Tier CFC - McDermott Will & Emery

Subpart F: Sale of a Lower-Tier CFC

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Overview


Lowell Yoder authored this bylined article discussing the treatment of the sale of a controlled foreign corporation (CFC) by a CFC under new Tax Reform regulations. He describes the application of the Subpart F income rules, the GILTI rules and the dividends received deduction.