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Ownership Attribution Under Section 958 Including for Purposes of Determining Status as Controlled Foreign Corporation or United States Shareholder

tax-irs · IRS · Rule · Published 2020-09-22 · Effective 2020-09-22 · 85 FR 59428

Document

Document number
2020-17549
Federal Register citation
85 FR 59428
CFR reference
26 CFR 1
Type
Rule
Action
Final regulations.
Category
tax-irs
Sub-agency
IRS
Publication date
2020-09-22
Effective date
2020-09-22
Treasury docket
TD 9908

Abstract

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.

Source

Authoritative
Federal Register document
Machine
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