It’s a Complex World for Troubled CFCs’ Tax Attributes

By: Emily L. Foster

How the rules that limit the ability to use tax attributes following a loss corporation’s ownership change apply to controlled foreign corporations is fraught with unanswered questions and in need of quick guidance.

Before the Tax Cuts and Jobs Act, applying section 382 rules to CFCs wasn’t really on practitioners’ radar, Sara B. Zablotney of Kirkland & Ellis LLP said January 19 during a New York State Bar Association Tax Section virtual meeting.

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By Emily L. Foster, posted on Monday January 25, 2021

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