Managing Director Kevin M. Jacobs Featured in Tax Notes
The recent International Fiscal Association USA branch’s conference highlighted crucial regulatory developments in international taxation, including regulations concerning downward attribution, "faux controlled foreign corporations," and exceptions from foreign personal holding company income. However, these regulations are not currently a high priority for the IRS, and there is no estimated timeline for finalization.
One of the key regulatory changes initiated by the Tax Cuts and Jobs Act involved the repeal of Section 958(b)(4), resulting in the creation of many controlled foreign corporations (CFCs). The proposed regulations aim to amend rules concerning the subpart F exception provided by section 954(c)(6), which applies to certain payments between related CFCs. Concerns have been raised regarding the retroactivity of these regulations and the potential necessity for taxpayers to file amended returns.
In a recent Tax Notes article, "Finalization of Downward Attribution Regs Not a High Priority," A&M Tax Managing Director Kevin M. Jacobs raised questions about the potential outcomes of these regulations and their impact on taxpayers, particularly concerning retroactivity and the necessity for amended returns. The discussion highlighted the ongoing uncertainty surrounding the finalization of these regulations and the challenges tax professionals face in navigating the proposed changes.
