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

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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.