This is the table of contents of Internal Revenue Bulletin IRB 2020-42. Click on an entry to view the entry. Items shown under "Highlights of This Issue" open summaries of each IRB-referenced document only. Scroll to Parts I, II, etc. to view the full text versions of each IRB-referenced document. Use the "Keyword Search" option of TouchTax to search the full text of all Internal Revenue Bulletins, including this IRB.
These synopses are intended only as aids to the reader in identifying the subject matter covered. They may not be relied upon as authoritative interpretations.
This document contains proposed regulations under sections 367 and 954 relating to ownership attribution through foreign entities as a result of the repeal of section 958(b)(4). The proposed regulations generally limit the application of the look-through rule in section 954(c)(6) to foreign corporations that are controlled foreign corporations without regard to downward attribution from foreign persons and modify certain ownership attribution rules under section 367(a) that reference section 958(b)(4).
This document contains final regulations under sections 267, 332, 367, 672, 706, 863, 904, 958, and 6049 relating to ownership attribution through foreign entities as a result of the repeal of section 958(b)(4). The final regulations generally limit the application of certain rules only to foreign corporations that are controlled foreign corporations without regard to downward attribution from foreign persons. The final regulations also provide rules on how to determine ownership for purposes of certain rules in the Code that directly or indirectly reference section 958(b)(4).
26 CFR 1.267(a)-3; 1.332-8; 1.367(a)-8; 1.672(f)-2; 1.706-1; 1.863-8; 1.863-9; 1.904-5; 1.958-2; 1.6049-5
The Internal Revenue Bulletin is produced and published by the Internal Revenue Service and contains IRS pronouncements affecting tax analysis under the Code and the Regulations, including but not limited to Revenue Procedures, Revenue Rulings, Notices and Announcements. Access the IRS site at https://www.irs.gov/help/irsgov-accessibility for information concerning accessibility of IRS materials. While every effort has been made to ensure that the IRB database files available through the TouchTax application are accurate, those using TouchTax for legal research should verify their results against the printed versions of the IRBs available from the IRS.