# Revisions of the Section 338 Consistency Rules With Respect to Target Affiliates That Are Controlled Foreign Corporations
> **IRS** · Final regulations. · Published 1997-01-23 · Effective 1997-01-20 · 62 FR 3458
## Document
- **Document number:** 97-1521
- **Category:** tax-irs
- **Sub-agency:** IRS
- **Federal Register citation:** 62 FR 3458
- **CFR reference:** 26 CFR 1
- **Publication date:** 1997-01-23
- **Effective date:** 1997-01-20
- **Treasury docket:** TD 8710
## Abstract

This document contains final regulations relating to the consistency rules under section 338 of the Internal Revenue Code of 1986 that are applicable to certain cases involving controlled foreign corporations. The final regulations substantially revise and simplify the stock and asset consistency rules. The final regulations include the provisions of the consistency rules applicable to controlled foreign corporations contained in recent proposed and temporary regulations. The final regulations would affect taxpayers that own controlled foreign corporations.

## Source
- [Federal Register document](https://www.federalregister.gov/documents/1997/01/23/97-1521/revisions-of-the-section-338-consistency-rules-with-respect-to-target-affiliates-that-are-controlled)
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