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Tiered CFCs and Inbound Exchanges

8 Pages Posted: 31 Aug 2007  

Rebecca M. Kysar

Brooklyn Law School; Fordham University School of Law

Abstract

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)

Brooklyn Law School ( email )

250 Joralemon Street
Brooklyn, NY 11201
United States

Fordham University School of Law ( email )

113 West 60th Street
New York, NY 10023
United States

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