Treasury and IRS Issue Proposed Regulations for Section 956
Posted on Oct 31, 2018 in International Tax
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 Jobs Act. Public comments on the proposed regulations are due within 30 days of their publication in the Federal Register.
Read Proposed Regulations: REG-114540-18: Amount Determined Under Section 956 for Corporate United States Shareholders