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I.R.S. Proposed New Partnership Rules Under Code §956

Volume 2 No 8   |   Read Article

By Andrew P. Mitchel and Kenneth Lobo

The I.R.S. recently released temporary and proposed regulations to limit the use of foreign partnerships to avoid income inclusions under Code §956. The Temporary Regulations are more limited in their scope while the Proposed Regulations are quite broad. If finalized in the current form, the Proposed Regulations would cause most C.F.C. loans to partnerships with related U.S. partners to be investments in U.S. property.  See more →