Revisions of the Section 338 Consistency Rules With Respect to Target Affiliates That Are Controlled Foreign Corporations

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These amendments to the income regulations revise the consistency rules under section 338 of the Internal Revenue Code of 1986 applicable to certain cases involving controlled foreign corporations. This action is necessary to simplify and update the existing regulations. These regulations are substantially identical to the consistency rules applicable to controlled foreign corporations contained in recent proposed regulations. The regulations would affect taxpayers that own controlled foreign corporations. The text of these temporary regulations also serves as the text of the proposed regulations set forth in the notice of proposed rulemaking on this subject in the Proposed Rules section of this issue of the Federal Register.