Department of Treasury September 22, 2020 – Federal Register Recent Federal Regulation Documents

Ownership Attribution Under Section 958 for Purposes of Sections 367(a) and 954(c)(6)
Document Number: 2020-17550
Type: Proposed Rule
Date: 2020-09-22
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains proposed regulations relating to the modification of section 958(b) of the Internal Revenue Code (``Code'') by the Tax Cuts and Jobs Act, which was enacted on December 22, 2017. The proposed regulations modify the ownership attribution rules applicable to outbound transfers of stock or securities of a domestic corporation under section 367(a). The proposed regulations also narrow the scope of foreign corporations that are treated as controlled foreign corporations for purposes of the look-through rule under section 954(c)(6). The proposed regulations affect United States persons that transfer stock or securities of a domestic corporation to a foreign corporation that are subject to section 367(a), and United States shareholders of foreign corporations.
Ownership Attribution Under Section 958 Including for Purposes of Determining Status as Controlled Foreign Corporation or United States Shareholder
Document Number: 2020-17549
Type: Rule
Date: 2020-09-22
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains final regulations relating to the modification of section 958(b) of the Internal Revenue Code (``Code'') by the Tax Cuts and Jobs Act, which was enacted on December 22, 2017. This document finalizes the proposed regulations published on October 2, 2019. The final regulations affect United States persons that have ownership interests in, or that make or receive payments to or from, certain foreign corporations.