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IRS finalizes stock attribution rules

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Tax Hot Topics newsletter The IRS released final regulations (T.D. 9883) on Nov. 18 that adopt previously issued proposed regulations (REG-125135-15) without change. The regulations provide rules regarding the attribution of stock for purposes of determining whether a person is a “related person” with respect to a Controlled Foreign Corporation (CFC) under Section 954(d)(3). The rules also contains guidance with respect to the active rents exception for Foreign Personal Holding Company Income (FPHCI), and implements anti-abuse rules related to the use of options.

Prior coverage on the proposed regulations can be found here.

Contact:
David Sites
Partner, Washington National Tax Office
T +1 202 861 4104

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