The Final Regulations from the U.S. IRS and Treasury on Ownership Attribution for Purposes of Determining Whether a Person Is Related to a Controlled Foreign Corporation; Rents Derived in the Active Conduct of a Trade or Business were published in the Federal Register on 19 November 2019 and are effective from that date.
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SUMMARY:
This document contains final regulations regarding the attribution of ownership of stock or other interests for purposes of determining whether a person is …