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Earnings and profits of lower-tier foreign subsidiaries described in Section 1248(c)(2) should be taken into account when gain is recognized with respect to stock of a controlled foreign corporation, according to final IRS regulations. The final rules generally adopt 2009 rules characterizing gain recognized with respect to stock in foreign corporations upon distributions. The rules affect distributions occurring on or after Feb. 10, 2009. The 2009 regulations provided that gain recognized under Section 301(c)(3) in connection with the receipt of a distribution of property from a foreign corporation with respect to its stock shall be treated as gain from the sale or exchange of the stock of such foreign corporation for purposes of Section 1248(a).
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