The Tax Cuts and Jobs Act of 2017 continues to reverberate even unto the end of 2020. Our International Tax Group discusses a letter ruling that may have been a harbinger of proposed regulations to address exceptions to Section 367(a) gain recognition in light of the TCJA’s repeal of Section 958(b)(4).
- The specter of foreign-to-U.S. downward attribution
- Curtailing collateral effects of the repeal of Section 958(b)(4)
- Proposed regulations formalize pre-TCJA approach in targeted Section 367(a) context
Click here to read the full advisory.