Final Regulations Partially Mitigate Overbroad Controlled Foreign Corporation Attribution Rules Passed as Part of 2017 U.S. Tax Reform
The U.S. Internal Revenue Service (“IRS”) recently finalized tax regulations under its complex controlled foreign corporation (“CFC”) regime that partially mitigate some of the harsh tax consequences resulting from an apparent drafting error contained in the 2017 U.S. tax reform legislation. The 2017 US tax ...
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