This Week’s Internal Revenue Bulletin

HIGHLIGHTS OF THIS ISSUE

These synopses are intended only as aids to the reader in identifying the subject matter covered. They may not be relied upon as authoritative interpretations.

INCOME TAX

REG-110059-20, page 904. This document contains proposed regulations under sections 367 and 954 relating to ownership attribution through foreign entities as a result of the repeal of section 958(b)(4). The proposed regulations generally limit the application of the look-through rule in section 954(c)(6) to foreign corporations that are controlled foreign corporations without regard to downward attribution from foreign persons and modify certain ownership attribution rules under section 367(a) that reference section 958(b)(4).

T.D. 9908, page 894. This document contains final regulations under sections 267, 332, 367, 672, 706, 863, 904, 958, and 6049 relating to ownership attribution through foreign entities as a result of the repeal of section 958(b)(4). The final regulations generally limit the application of certain rules only to foreign corporations that are controlled foreign corporations without regard to downward attribution from foreign persons. The final regulations also provide rules on how to determine ownership for purposes of certain rules in the Code that directly or indirectly reference section 958(b)(4).