The U.S. IRS and Treasury have released proposed regulations 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 (REG-125135-15). The regulations are to generally apply for taxable years of CFCs ending on or after the date they are published as final regulations, although CFCs may rely on the rules for taxable years ending on or after 17 May 2019, provided that they con…