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Tiered CFCs and Inbound Exchanges

Rebecca M. Kysar

Brooklyn Law School

Tax Notes, Vol. 116, No. 13, September 24, 2007

Recently issued final regulations under sections 367(b) and 1248 clarify the amount of earnings and profits taken into account by some U.S. shareholders upon an otherwise tax-free inbound exchange of the stock or assets of the parent of a tiered group of controlled foreign corporations. This article explains the rationale underlying the clarification, which was not articulated in its issuance, and endorses it from both technical and policy perspectives.

Number of Pages in PDF File: 8

Keywords: taxation, international taxation

JEL Classification: K34, H20, H25

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Date posted: August 31, 2007  

Suggested Citation

Kysar, Rebecca M., Tiered CFCs and Inbound Exchanges. Tax Notes, Vol. 116, No. 13, September 24, 2007. Available at SSRN: http://ssrn.com/abstract=1011100

Contact Information

Rebecca M. Kysar (Contact Author)
Brooklyn Law School ( email )
250 Joralemon Street
Brooklyn, NY 11201
United States

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