OrbitaxU.S. Publishes Regulations on CFCs, Foreign Partnerships and Active the Rents and Royalties Exception
|Approved Changes|United States
On 2 September 2015, the U.S. Department of Treasury and IRS published final and temporary regulations concerning CFC anti-avoidance rules, foreign partnerships distributions funded by a CFC, and eligibility for the active rents and royalties exception.
Modifications of Anti-Avoidance Rule in § 1.956-1T(b)(4)
The anti-avoidance rule in § 1.956-1T(b)(4), which generally applies to treat one C…
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