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Client Alert September 24, 2020
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.
Tax and Wealth Services Report Blog September 2, 2020
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.