Eversheds Sutherland Tax Reform Law Blog
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Treasury and IRS Issue Proposed Regulations for Section 956

Treasury and the IRS have issued proposed regulations (REG-114540-18) that would reduce the inclusion determined under section 956 for certain domestic corporations that own stock in controlled foreign corporations.   The proposed regulations are intended to harmonize the application of section 956 and the participation exemption system (section 245A) enacted under the Tax Cuts and...