Proposed regulations will reduce the Code Sec. 956 amount for certain domestic corporations that own stock in controlled foreign corporations (CFCs). The proposed regulations are intended to ensure that Code Sec. 956 is applied consistently with the new participation exemption system under Code Sec. 245A. Subpart F Rules Under the subpart F rules, U.S. shareholders […]
The post Proposed Regulations Reduce Section 956 Income Inclusions by Domestic Corporations Owning CFC Stock (NPRM REG-114540-18; IR-2018-210) appeared first on Tax & Accounting Blog.