Proposed regulations and Rev. Proc. 2019-40 address repeal of Section 958(b)(4)

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October 2019

Overview

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 takeaway

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.

Contact us

Oren Penn

Principal, US Inbound Tax and International Tax Services, PwC US

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