Christine Hradsky No Comments

Foreign Tax Technical Update- Section 956

PROPOSED REGULATIONS REDUCING THE AMOUNT DETERMINED UNDER SECTION 956 WITH RESPECT TO CERTAIN DOMESTIC CORPORATIONS ISSUED

Summary

On October 31, the Department of the Treasury and the Internal Revenue Service (collectively, Treasury) issued proposed regulations under Section 956, Investment of earnings in United States property, (the Proposed Regulations). The Proposed Regulations reduce the amount determined under Section 956 with respect to certain domestic corporations that own (or are treated as owning) stock in foreign corporations. Read more