Proposed Regulations implement OBBBA changes to income inclusions resulting from sales of controlled foreign corporation stock

On August 26, the Treasury Department published proposed regulations (the “Proposed Regulations”) under Code sections 951 and 951A addressing the determination of a U.S. shareholder’s pro rata share of subpart F income, tested income, and tested loss of a controlled foreign corporation (“CFC”).... By: Hogan Lovells Cadwalader