The U.S. IRS and Treasury have issued final regulations on Ownership Attribution Under Section 958 Including for Purposes of Determining Status as Controlled Foreign Corporation or United States Shareholder (TD 9908), published in the Federal Register on 22 September 2020. The regulations provide relief to taxpayers affected by the repeal of section 958(b)(4) by the Tax Cuts and Jobs Act, which provided an exception for subpart F purposes to downward attribution of CFC stock held by a foreign person to a U.S. shareholder. This includes modifications to existing regulations that are intended to ensure, in certain appropriate circumstances, that the...