Websection 958(b) (relating to constructive ownership rules with respect to controlled foreign corporations); and I.R.C. § 318(b)(8) — section 6038(e)(2) (relating to information with … Web6 Jan 2024 · The repeal of 958 (b) (4) was intended to prevent a US corporation (that owned a CFC) that underwent an inversion, from escaping US shareholder status post-inversion. However, the ramifications of the …

26 CFR § 1.958-1 - Direct and indirect ownership of stock.

WebSection 958(b) provides, in relevant part, that Section 318(a), relating to the constructive ownership of stock, applies, subject to certain modifications, to the extent that the effect … WebIf a foreign corporation is a controlled foreign corporation at any time during any taxable year, every person who is a United States shareholder (as defined in subsection (b)) of … blood in an eye

The Downward Spiral of Downward Attribution

Web1 Jun 2024 · One of the most disruptive and wide-reaching changes was the repeal of Section 958 (b) (4), which historically had prevented the downward attribution of stock from foreign persons to U.S. entities in the context of the … WebDescription. As part of the Tax Cuts and Jobs Act (TCJA), Section 958(b)(4) was repealed. The repeal of Section 958(b)(4) modified the rules for determining U.S. shareholder and CFC status and thus, increased the number of foreign subsidiaries subject to the CFC anti-deferral provisions. The Subpart F rules generally require U.S. shareholders of CFCs to … WebSection 958(b) sets forth constructive ownership rules that apply to determine whether a U.S. person is a “U.S. shareholder” and a foreign corporation is a CFC. A CFC is a foreign corporation in which “U.S. shareholders” own (directly, indirectly or constructively) more than 50 percent of the vote or value of the corporation’s outstanding shares. free craft ideas for spring