Treasury Sees Guidance This Summer on Foreign-Owned Companies

The Treasury Department is aiming to issue guidance in the next few months regarding a new anti-abuse rule for foreign-owned US companies, an agency official said Thursday.

Treasury is “actively working” on the guidance under Section 951B, said Jared Hermann, a Treasury attorney-advisor, speaking at a Federal Bar Association insurance-tax seminar in Washington.

“The goal is later this summer,” Hermann told a reporter after he spoke.

The change, part of the giant 2025 tax-and-spending law, applies to foreign-controlled US companies that in turn own foreign corporations. Such situations can involve “sandwich structures” that lawmakers see as potentially abusive, ...