Revised Reg. §1.956-1T(b)(4) Expands the Indirect Investment Rule

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Overview


In Depth


Lowell Yoder wrote this bylined article on revised temporary Treasury and IRS regulations that expand the §956 indirect investment rule regarding transfer of funds by a controlled foreign corporation to a related foreign corporation. Taxpayers using the revised rule “will frequently have strong arguments for why the transfer of funds should not be considered to have a principal purpose of avoiding §956, but careful analysis is recommended,” Mr. Yoder wrote. Read the full article.