IRS Takes Flawed Approach to Inclusion Under Subpart F

Publication
May 2009
Journal of Taxation
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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. 
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