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Section 367(a)

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

November 23, 2020 By Edward Tanenbaum and Heather Ripley

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 attributionCurtailing 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. [...]Read more

Filed Under: International Tax Advisory Tagged With: IRS, Letter Ruling, Section 367(a), Section 958(b)(4), Tax Cuts and Jobs Act, tax reform, TCJA

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