The Internal Revenue Service today issued proposed regulations reducing the amount determined under Internal Revenue Code section 956 for certain domestic corporations that own (or are treated as owning) stock in controlled foreign corporations (CFCs).
The Tax Cuts and Jobs Act (TCJA), passed in December 2017, made major changes to the tax law, including enacting a participation exemption system for the taxation of certain foreign income. The new proposed regulations are intended to ensure that the application of section 956 is consistent with the new participation exemption system.
Treasury and IRS welcome public comments on these proposed regulations. For details on submitting comments, see the proposed regulations.
Updates on the implementation of the TCJA can be found on the Tax Reform page of IRS.gov.