The U.S. IRS and Treasury have issued final regulations providing Guidance Under Section 958 on Determining Stock Ownership (TD 9960), which were published in the Federal Register on 25 January 2022. The regulations concern the treatment of domestic partnerships for purposes of determining amounts included in the gross income of their partners with respect to foreign corporations. The regulations generally apply in respect of taxable years of foreign corporations beginning on or after 25 January 2022, although certain aspects may be applied by domestic partnerships to taxable years of a foreign corporation beginning after 31 December 2017. In connection with...