IRS to Issue Rules Addressing Abusive CFC Loans to Foreign Partnerships

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May 1 — The IRS has nearly completed regulations intended to halt certain tax-avoiding loans by controlled foreign corporations to foreign partnerships, a senior agency official said.

Jason T. Smyczek, Internal Revenue Service senior technical reviewer, Branch 4, associate chief counsel (International), called the long-awaited Section 956 guidance project a “high priority” for the government. Smyczek said April 30 that the regulations would be released “very soon.”

“We are very far along. And we think we've made a lot of progress to answer this question. It is on our priority guidance list,” he said. “It is definitely one the high-priority items.”

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