Faux CFCs and Restoration of the Prohibition on Downward Attribution
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Faux CFCs and Restoration of the Prohibition on Downward Attribution
Lee A. Sheppard examines a provision in the One Big Beautiful Bill Act that restores, with some exceptions for specified foreign parent situations, the prohibition on downward attribution that the Tax Cuts and Jobs Act repealed, saying that the IRS and Treasury will need to rescind or reengineer guidance issued while the prohibition was repealed.
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