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This Section Applies to Persons Who Have Previousl Form

This Section Applies to Persons Who Have Previousl Form

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Instructions and help about fss certificate

[Music] in revenue ruling 90-31 a u.s person owned 100 of the shares of a controlled foreign corporation or a cfc the u.s person had a tax basis in the shares of 60. the section 1248 amount was 30. the u.s person sold the shares of the cfc for 100 of cash recognizing a gain of 40. 30 of the gain was recharacterized as a dividend under section 1248 the buyer took a basis in the shares of the cfc of a hundred the amount paid for the shares however the section 1248 gain recognized by the seller created 30 of previously taxed income or pti in the cfc thus when the cfc made a distribution to the buyer of 40 30 of the distribution was out of pti and therefore was not taxable to the buyer the 10 in excess of the pti was taxable as a dividend to the buyer distributions of pti from a cfc to a u.s shareholder cause a reduction in the basis of the cfc shares thus the buyer's basis in the shares is reduced from 100 to 70 as a result of the 30 pti distribution [Music]

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