U.S. Proposed Regulations on Reducing the Amount Determined Under Internal Revenue Code Section 956 for Domestic Corporations Owning CFCs
On 5 November 2018, a document containing proposed regulations for Internal Revenue Code section 956 (REG-114540-18) was published in the U.S. Federal Register. The proposed regulations reduce the amount determined under section 956 for certain domestic corporations that own (or are treated as owning) stock in controlled foreign corporations (CFCs) in order to ensure that the applica…
Continue Reading