Epstein, Stephen J.
March 2003
Financial Executive;Mar/Apr2003, Vol. 19 Issue 2, p64
Academic Journal
The article surveys tax issues surrounding the sale and acquisition of foreign assets. Discussion focuses on relevant sections of the U.S. Internal Revenue Code. The author notes how Section 338 of the Code offers tax benefits under certain circumstances. Both purchases and sales involving Controlled Foreign Corporations are discussed, as are foreign tax credits. In addition, the author notes tax implications for U.S. citizens of sales involving S corporations and partnerships. Capital gains taxes are treated as well. INSET: Initial Result of Section 338(g) Election.


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