Executive summaryOn 21 September 2020, the United States (US) Treasury Department (Treasury) and the Internal Revenue Service (IRS) released final regulations (TD 9908) and proposed regulations (REG-110059-20) on the repeal of Internal Revenue Code1 Section 958(b)(4) by the Tax Cuts and Jobs Act (TCJA). The regulations do not undo the repeal of Section 958(b)(4). Instead, the regulations modify certain provisions so they apply in a manner consistent with their application before the repeal of Section 958(b)(4).The final regulations generally adopt, with some changes, the proposed regulations that were issued on 2 October 2019 (2019 proposed regulations). The new proposed regulations would modify the application...