Non-publicly traded controlled foreign corporation
Non-publicly traded controlled foreign corporation (1)In general.For purposes of section 1297, the assets of a controlled foreign corporation that is not described inparagraph (d)(1)(v)(A)of this section (including assets treated as held pursuant to section 1297(c) and 1.12972(b)(2)(i) and (b)(3)(i), other than assets held by a look-through subsidiary described inparagraph (d)(1)(v)(A)of this section) must be measured for all measuring periods of the taxable year during which the foreign corporation is a controlled foreign corporation on the basis of adjusted basis.