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On September 21, 2020, the IRS released for publication final regulations (T.D. 9908) relating to the modification of section 958(b) by the Tax Cuts and Jobs Act (“TCJA”). These regulations affect U.S. persons that have ownership interest in, or that make or receive payments to or from, certain foreign corporations. By way of background, section 958(b)(4) prevented “downward attribution” of stock owned by a foreign person to a U.S. person.
Updated: May 25, 2018: JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.
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