Page 166 - International Taxation IRS Training Guides

Other TCJA Changes Related to

Participation Exemption

providing that gain from the sale or exchange
 Rules

of foreign corporation stock that i s
treated as a
dividend is
eligible for participation exemption (IRC

1248(j))

rules apply with respect to the sale by a CFC of a lower-tier
 Similar
CFC (IRC 964(e)(4))

 Rules providing basis
adjustment for foreign
corporation stock
upon sale (IRC 961(d))

 Effective after
Dec. 31, 2017

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