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Down the Rabbit Hole: Guidance Addressing Downward Attribution After Repeal of Section 958(b)(4)

October 15, 2019 By Edward Tanenbaum and Daniel Reach

The IRS released Proposed Regulations and a Revenue Procedure addressing the Tax Cuts and Jobs Act’s repeal of Section 958(b)(4). Our International Tax Group explores how this guidance affects numerous provisions of the Code.

  • Downward attribution beyond Subpart F, GILTI, and Section 965
  • Silence on the portfolio interest exemption
  • Safe harbors and eased reporting requirements

Read the full advisory here.

Filed Under: International Tax Advisory Tagged With: 958(b)(4), GILTI, IRS, portfolio interest exemption, proposed regulations, Revenue Procedure, safe harbor, section 965, Subpart F, Tax Cuts and Jobs Act, tax refrom

About Edward Tanenbaum

Edward Tanenbaum is co-chair of the firm’s Federal & International Tax Group and a member of the firm’s Global Resources & Strategies Committee. Mr. Tanenbaum’s practice consists primarily of planning and structuring tax efficient solutions for cross-border business transactions and investments by foreign multinational corporations and high-net-worth individuals.

[Read Bio]

About Daniel Reach

Danny Reach is an associate in the Federal and International Tax Group. His practice includes federal and international tax planning, and he has particular experience with the tax aspects of derivative financial instruments.

[Read Bio]

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