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Final and Proposed Regulations Focus on U.S. Property Held by Controlled Foreign Corporations in Partnership Transactions (T.D. 9792; NPRM REG-114734-16; NPRM REG-122387-16)

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CCH Tax Day Report The IRS has issued final regulations under Code Sec. 956 addressing U.S. property held by controlled foreign corporations (CFCs) in transactions involving partnerships, along with related proposed regulations, and has partially withdrawal some earlier proposed regulations. Code Sec. 956 determines the amount that a U.S. shareholder (as defined in Code Sec. […]

The post Final and Proposed Regulations Focus on U.S. Property Held by Controlled Foreign Corporations in Partnership Transactions (T.D. 9792; NPRM REG-114734-16; NPRM REG-122387-16) appeared first on Tax & Accounting Blog.


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