Two New IRS Rules Aim to Help Stock Attribution Woes (3)

U.S. companies now have final IRS rules that help limit the scope of a 2017 tax law change negatively affecting foreign corporations, as well as new proposed rules that offer additional relief.

The IRS on Monday released a set of final rules (RIN 1545–B052) that modify existing regulations in a way that is consistent with how the rule operated prior to the repeal of downward attribution rules under Section 958(b)(4).

The repeal of that section caused the downward attribution of stock from a foreign person to a U.S. person, the IRS has said.

The final rules affect U.S. ...