Internal Revenue Service May 20, 2019 – Federal Register Recent Federal Regulation Documents

Ownership Attribution for Purposes of Determining Whether a Person Is Related to a Controlled Foreign Corporation; Rents Derived in the Active Conduct of a Trade or Business
Document Number: 2019-10464
Type: Proposed Rule
Date: 2019-05-20
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains proposed regulations that provide rules regarding the attribution of ownership of stock or other interests for purposes of determining whether a person is a related person with respect to a controlled foreign corporation (CFC) under section 954(d)(3). In addition, the proposed regulations provide rules for determining whether a CFC is considered to derive rents in the active conduct of a trade or business for purposes of computing foreign personal holding company income (FPHCI). The regulations would affect United States persons with direct or indirect ownership interests in certain foreign corporations.
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