Web1 Jun 2024 · Section 958 (b) (4) Repeal and the Proliferation of the Constructive CFC. The impact of the Tax Cuts and Jobs Act (TCJA) was particularly significant in the cross … Web21 Jun 2024 · According to the legislative history to the 1962 Act, section 958(a) is a “limited rule of stock ownership for determining the amount taxable to a United States …

The Downward Spiral of Downward Attribution

WebControlled foreign corporation (“CFC”): A CFC is a foreign corporation with U.S. shareholders that own (directly, indirectly, or constructively, within the meaning of Section 958(a) and 958(b)) on any day of its taxable year, more than 50% of either 1) the total combined voting power of all classes of its voting stock, or 2) the total value ... WebThe TCJA repealed IRC Section 958(b)(4), effective for the last tax year of a foreign corporation beginning before January 1, 2024. The impact of IRC Section 958(b)(4)'s … fresh script

Treasury and IRS Finalize Targeted Guidance Addressing Section …

Web5 Oct 2024 · Section 958(b)(4) was repealed by the Tax Cuts and Jobs Act in an effort to narrowly target “de-control” transactions in which a foreign parent of a U.S. shareholder … WebSection 958 (a) provides that, for purposes of sections 951 to 964 (other than sections 955 (b) (1) (A) and (B) and 955 (c) (2) (A) (ii) (as in effect before the enactment of the Tax Reduction Act of 1975 ), and 960 (a) (1)), stock owned means - (1) Stock owned directly; and (2) Stock owned with the application of paragraph (b) of this section. WebA person (other than a publicly traded corporation or partnership) is a Majority US-Owned Person if RPII US Shareholders collectively own (using direct, indirect and constructive ownership principles in IRC Section 958(a) and (b)) (1) more than 50% of the stock in the person if it is a corporation, (2) more than 50% of the capital and profits ... father and his family