How the U.S. Treats Foreign Corporations and Trusts

Bilzin Sumberg congratulates Litigation Partner, Melissa Pallett-Vasquez, on her appointment as Vice Chair of the Food, Agriculture & Cannabis Committee of the American Bar Association's International Law Section. 

This article briefly summarizes the attribution rules applicable to partnerships and corporations under Section 318 and provides some practical tips for dealing with the rules.

On September 21, 2020, the IRS finalized (with certain modifications) proposed regulations that had been issued last year regarding some of the unintended consequences of the downward attribution rules under Section 958(b), and issued another set of proposed regulations.