What question did this study set out to answer?

This article aims to evaluate the advantages of the individual limitation on taxing sales of controlled foreign corporation stock as defined under Section 1248(b).

June 15, 2026Journal of the American Taxation Association

Section 1248(b): The individual Limitation on Taxing Sales of CGC Stock Offers Substantial Tax Savings.

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This article aims to evaluate the advantages of the individual limitation on taxing sales of controlled foreign corporation stock as defined under Section 1248(b).
Examine the applicability and calculation of Section 1248(b) tax limitations.
Compare tax liabilities under Sections 1248(a) and 1248(b).
Analyze how various tax rates affect effective U.S. taxes on Section 1248(a) dividend income.
Section 1248(b) offers substantial tax savings compared to the limitations imposed by Section 1248(a).
Numerous transactions that incur tax liabilities fall outside the scope of Section 1248 provisions.
The effective U.S. tax rate on Section 1248(a) dividend income can vary significantly based on corporate and individual tax rates.

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Implication

Analysis explores tax savings from Section 1248(b) limitation on CFC stock sales, suggesting significant benefits.

Cite This Study

Kramer et al. (1981) studied this question.

synapsesocial.com/papers/6a2f973ca1cfeec4908284ae https://doi.org/10.2308/jata-6147677

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Section 1248(b): The individual Limitation on Taxing Sales of CGC Stock Offers Substantial Tax Savings.

Key Points

Discussion

Implication

Cite This Study

Section 1248(b): The individual Limitation on Taxing Sales of CGC Stock Offers Substantial Tax Savings.

Key Points

Discussion

Implication

Cite This Study

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