Tiered CFCs and Inbound Exchanges

8 Pages Posted: 31 Aug 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.

Keywords: taxation, international taxation

JEL Classification: K34, H20, H25

Suggested Citation

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

Rebecca M. Kysar (Contact Author)

Fordham University School of Law ( email )

150 West 62nd Street
New York, NY 10023
United States

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