IRS Prop. Reg.: Comments Submitted on Ownership Attribution Applicable to Outbound Transfers of Stock or Securities of a Domestic Corporation (IRC §958)

Public comments released November 17 on REG-110059-20 that would modify the ownership attribution rules applicable to outbound transfers of stock or securities of a domestic corporation under tax code Section 367(a). The proposed regulations for Section 958(b) (modified under the 2017 TCJA) would narrow the scope of foreign corporations that are treated as controlled foreign corporations (CFCs) for purposes of the look-through rule under Section 954(c)(6). [Comments from United States Council for International Business (USCIB)]

Reference:
View Source Document.