Treasury and the IRS on October 1 released proposed regulations addressing various provisions of the Code impacted by the repeal of Section 958(b)(4) as part of the 2017 tax reform legislation (the Act) together with a Revenue Procedure providing safe harbors for complying with provisions relevant to controlled foreign corporations (CFCs) in light of such repeal.
The proposed regulations and Rev. Proc. 2019-40 should be reviewed in order to determine potential impacts and potential relief on related reporting requirements if a US person is considered to own an interest in a CFC as a result of the repeal of Section 958(b)(4).
PwC will publish an Insight with more analysis in the coming days.