U.S. IRS Issues Final and Proposed Regulations on Ownership Attribution Including for Purposes of Determining Status as CFC or U.S. Shareholder

The U.S. IRS and Treasury have issued final regulations on Ownership Attribution Under Section 958 Including for Purposes of Determining Status as Controlled Foreign Corporation or United States Shareholder (TD 9908), published in the Federal Register on 22 September 2020. The regulations provide relief to taxpayers affected by the repeal of section 958(b)(4) by the Tax Cuts and Jobs Act, which provided an exception for subpart F purposes to downward attribution of CFC stock held by a foreig…