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 CFC as holding property actually held by another CFC when one funds the other, is modified to also apply when funded other than through capital contributions or debt. In addition, § 1.956-1T(b)(4) is expanded to include transactions involving partnerships that are controlled by a CFC....