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US: Final and proposed regulations limit impact of repeal of Section 958(b)(4)

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United States

Executive summary

On 21 September 2020, the United States (US) Treasury Department (Treasury) and the Internal Revenue Service (IRS) released final regulations (TD 9908) and proposed regulations (REG-110059-20) on the repeal of Internal Revenue Code1 Section 958(b)(4) by the Tax Cuts and Jobs Act (TCJA). The regulations do not undo the repeal of Section 958(b)(4). Instead, the regula…

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