Treasury and IRS Release Final and Proposed Regulations on Downward Attribution under Section 958(b)
Posted on Sep 21, 2020 in International Tax
On September 21, the Department of the Treasury and the Internal Revenue Service released final and proposed regulations addressing the repeal of section 958(b)(4) by the Tax Cuts and Jobs Act (TCJA). Prior to the TJCA, section 958(b)(4) provided that section 318(a)(3) (downward attribution) did not apply to treat a US person as owning stock owned by a person who is a not a US person....
Proposed Regulations and New Revenue Procedure Address the Repeal of Section 958(b)(4)
Posted on Oct 1, 2019 in International Tax
Treasury and the IRS have released proposed regulations and a revenue procedure addressing the repeal of section 958(b)(4). Prior to its repeal by the Tax Cuts and Jobs Act, section 958(b)(4) prevented downward attribution from a foreign person for purposes of determining whether a foreign entity was a controlled foreign corporation under section 957. The proposed regulations address...