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U.S. IRS Practice Unit on IRC 958 Rules for Determining Stock Ownership

|Approved Changes|United States
United States

The U.S. IRS has published a practice unit on the IRC 958 Rules for Determining Stock Ownership. The general overview of the practice unit includes the following:

The objective of the subpart F provisions is to provide anti-deferral rules for certain foreign source income that is derived by certain foreign corporations by requiring certain U.S. persons to currently include the income as it is…

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