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

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.