id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
taxlaw-13768	Oosterhuis, Paul; Quinn Salazar, Mayté	Reflections on Section 367(b) Regulations and Inbound Transactions	2025	24	.pdf	application/pdf	11971	473	45	§ 1.367(b)-3 This review of past history spotlights an arguably fundamental error in assuming the paradigm of “deferral” with respect to the taxation of shareholders on foreign corporation earnings but not with respect to domestic corporation earnings. The expansion of shareholder taxation in Inbound Asset Reorganizations, beyond dealing with shareholder section 1248 Amounts—to tax the All E&P Amount rather than the section 1248 Amount of section 1248 Shareholders and to tax other U.S. taxpayers who are not U.S. Shareholders—serves as a proxy for the tax that should have been imposed at the corporate level but could not be because of the statutory limitations on the scope of section 367(b).	cache/taxlaw-13768.pdf	txt/taxlaw-13768.txt