Page 464 - Large Business IRS Training Guides
P. 464
New IRC 91
domestic corporation (DC) transfers
• If a
of the assets of a foreign branch
substantially all
(within the
meaning of former IRC 367(a)(3)(C)) to a
specified 10-percent owned FC (as defined in new
IRC 245A)
with respect to which it is a U.S.
after such transfer, DC must include in
shareholder
income,
in the tax year of the transfer, an amount
to the “Transferred Loss Amount”.
equal
• Effective
for transfers after December 31, 2017.
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