|
|
 |
|
|
Section 338 elections are typically used for U.S. dividend planning. The stepped-up tax bases are used for increased depreciation and amortization deductions in the computation of U.S. earnings and profits. U.S. earnings and profits decrease while foreign taxes stay the same. As a result, foreign tax credit is accelerated. Our valuation analyses establish the stepped-up inside basis of the assets to provide the starting point for the U.S. tax earnings and profits calculation.
|
|
|
|
