U.S. Publishes Regulations on CFCs, Foreign Partnerships and Active the Rents and Royalties Exception

On 2 September 2015, the U.S. Department of Treasury and IRS published final and temporary regulations concerning CFC anti-avoidance rules, foreign partnerships distributions funded by a CFC, and eligibility for the active rents and royalties exception.

Modifications of Anti-Avoidance Rule in § 1.956-1T(b)(4)

The anti-avoidance rule in § 1.956-1T(b)(4), which generally applies to treat one CFC as holding property actually held by another CFC when one funds the other, is modified to also ap…