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

摘要

In the Rules and Regulations portion of this issue of the Federal Register, the IRS is issuing temporary regulations revising the consistency rules under section 338 of the Internal Revenue Code of 1986 applicable to certain cases involving controlled foreign corporations. The text of those temporary regulations also serves as the text of these proposed regulations.