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Temporary Regulations Alter C.F.C.'s Active Rents and Royalties Exception to Subpart F

Volume 2 No 8   /   Read Article

By Christine Long and Nina Krauthamer

Newly issued temporary regulations (T.D. 9733) modify three of the six ways that rental or royalty income can qualify for the active exception to foreign personal holding company income (F.P.H.C.I.) under Subpart F. The new Treas. Reg. §1.954-2T addresses who can perform the required functions when a controlled foreign corporation (C.F.C.) leases or licenses property to an unrelated person, as well as the treatment of cost sharing arrangements.  See more →