IRS Floats Treating Some Foreign Branches In Pre-TCJA Way

Law360 (October 1, 2019, 10:56 AM EDT) -- The Internal Revenue Service proposed regulations Tuesday to provide some relief and restore continuity after a change under the 2017 federal tax overhaul that broadened the scope of offshore subsidiaries treated as controlled foreign corporations.

The Internal Revenue Service says proposed rules would limit the inquiries needed by those in the U.S. to determine whether certain foreign corporations are controlled foreign corporations or CFCs. (AP) The proposed regulations are generally intended to ensure that the operation of certain rules is consistent with their application before the Tax Cuts and Jobs Act repealed Internal Revenue Code Section 958(b)(4). Before it was removed,...

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