The US Treasury Department and Internal Revenue Service (IRS) have issued final regulations for determining the earnings and profits (E&P) attributable to stock of controlled foreign corporations (CFCs) under Section 1248 of the US Internal Revenue Code.
Section 1248 requires that all or a portion of the gain recognized on the sale or exchange of stock of a CFC by a US shareholder (i.e., an owner of 10% or more of the voting stock) will be treated as a div…