IRS Wants to Ease Pain of Inadvertent Foreign Corporation Owners

The IRS wants to soften the impact of a 2017 tax law change that caused shareholders to become owners of foreign corporations, an official said Wednesday.

Despite not having regulatory power to address the issue in all situations, the IRS is doing what it can to take the edge off a tax law change that is causing what’s known as “downward attribution,” said John Merrick, senior level counsel at the IRS’s Office of Associate Chief Counsel (International). He spoke during an online program hosted by the Practising Law Institute.

• The 2017 tax law repealed tax code Section 958(b)(4), ...