Insights
Day Pitney remains committed to providing quality legal counsel, while protecting our clients and employees, and transforming our communities into more just, equal and equitable spaces. For more information, please visit our COVID-19 Resource Center | Racial Justice and Equity Task Force.
Carl Merino, Dina Kapur Sanna and Seth Mersky co-authored an article, "Attribution After the TCJA: A Downward Spiral of Unintended Consequences," published by Trusts and Estates. The article focuses on the repeal of Internal Revenue Code Section 958(b)(4) as part of the Tax Cuts and Jobs Act of 2017 (TCJA). The repeal of this provision changed the rules for when ownership of stock of a foreign corporation can be attributed “downward” from a foreign shareholder, partner or beneficiary to a U.S. corporation, partnership trust or estate, causing many foreign companies that were not previously subject to the controlled foreign corporation (CFC) rules to become CFCs, with adverse tax consequences for both inbound and outbound investment structures.
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This website may use cookies, pixel tags and other passive tracking technologies, including Google Analytics, to improve functionality and performance. For more information, see our Privacy Policy. By using our website, you are consenting to our use of these tracking technologies. You can alter the configuration of your browser to refuse to accept cookies, but if you do so, it is possible that some areas of web sites that use cookies will not function properly when you view them. To learn more about how to delete and manage cookies, refer to the support instructions for each browser (e.g., see AllAboutCookies.org). You may locate Google Analytics' currently available opt-outs for the web here.