Alston & Bird Tax Blog

Letter Ruling Conjures Ghost of Section 958(b)(4) Past

By and

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.

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.

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About Heather Ripley

Heather Ripley is an associate in the firm’s Federal & International Tax Group. Her practice focuses on federal and international tax services for a range of clients, including domestic and international business entities and individuals.

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