IRC 338(g) Elections for Buyers of Controlled Foreign Corporation Stock in Wake of Major Changes
Section 1248(j) and 100% Dividends Received Deduction and Impact of GILTI Claiming Basis Step-Up
A live 110-minute CPE webinar with interactive Q&A
This webinar will provide tax advisers to individuals with a practical guide to the tax implications of Section 338(g) election on the purchase of controlled foreign corporation (CFC) stock. The panel will discuss the mechanics of taking a basis adjustment under IRC 338(g) and describe how the 2017 tax reform law changed the value calculation in determining whether a purchaser should make the election. The panel will provide tax planning strategies to optimize tax benefits and minimize pitfalls in the election under the new tax reform law.
- Mechanics of IRC 338(g) election
- General tax reform bill provisions impacting economic calculus of making a 338(g) election
- GILTI provisions
- New 1248(j) dividend treatment
- Planning opportunities
The panel will discuss these and other important topics:
- Scenarios under which a seller's tax cost may increase--or decrease--when a buyer of CFC stock makes a Section 338(g) election
- How the new Section 1248(j) provision intersects with the 100% dividends-received deduction of Section 245A
- Impact of GILTI on Section 338(g) election decisions
- How the 338(g) election can benefit post-sale integration and subsequent disposition of CFC stock
Pamela A. Fuller, JD, LLM
Tully Rinckey PLLC & Royse Law
Ms. Fuller advises a wide range of clients--including private and public companies, joint ventures, private equity... | Read More
Ms. Fuller advises a wide range of clients--including private and public companies, joint ventures, private equity funds, individuals, C-Suite executives, “start-ups,” and government entities--on transactional, investment, and supply-chain strategies to achieve optimal tax and business results. As a seasoned practitioner and tax technician, Ms. Fuller is accustomed to handling nuanced matters involving highly technical questions of law, policy, and procedure at the federal, state, local, and international levels. She provides sophisticated tax planning services across most industry sectors, including software & emerging digital technologies, financial services, real estate development, healthcare, pharmaceutical, construction & engineering, infrastructure, oil & energy, and retail.Close
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