A Glimmer of Hope for those suffering from the change in the CFC ownership attribution rules.
A representative at the Internal Revenue Service Office of Chief Counsel announced May 1st that the IRS and Treasury will be issuing proposed regulations addressing some of the non-Subpart F issues caused by the repeal of Section 958(b)(4).
Determining if a Foreign Company is a CFC
These regulations seek to provide some relief to taxpayers that have been impacted by the overly burdensome yet unintended consequences of the repeal of this provision.
No further information was provided as to what the relief may look like, only a cautionary note that the IRS and Treasury are limited to providing relief within their authority as interpreters of the law and not legislatures. This is welcome news indeed to the many taxpayers that have been waiting and hoping for this relief.
Stay tuned for more updates as it is released! If you have any further questions, please contact your Withum tax advisor by filling out the form below.
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