The U.S. IRS has released an international practice unit, Computation and Review of IRC 986(c) Gain or Loss - Pre-TCJA. The general overview of the practice unit is provided as follows:
When a controlled foreign corporation (CFC) of a U.S. Shareholder makes a distribution to that shareholder, the shareholder must determine whether it has previously taxed earnings and profits (PTEP) from that CFC in order to avoid double taxation. Internal Revenue Code (IRC) 959(a)(1) generally provides an e…