Page 648 - Large Business IRS Training Guides
P. 648
Anti-Abuse Rules
3
Sec. 965 Asset sale
meas. date
1/1/18 11/30/18 12/31/18 11/30/19 12/31/19
USP
CFC1 DISQUALIFIED PERIOD CFC1’s first inclusion year
CFC2 CFC2’s first inclusion year
245A
DRD
subject to GILTI under §951A: Gain realized by CFC1 is not tested
• Not
income because CFC1 realizes
the gain during the taxable year prior to
taxable year that GILTI applies to CFC1.
the first
64
