14 January 2016 Abusing Section 956 (BNA) James Tobin, a partner with Ernst & Young's International Tax Services group, recently authored an article published in BNA's Tax Management International Journal discussing the proposed and temporary regulations under Section 956, which expand (and propose to further expand) the instances requiring an income inclusion under Section 951(a)(1)(B) as a result of a CFC's holding US property. According to the article, the proposed and temporary Section 956 regulations address loans made by a CFC to a foreign partnership, particularly where the foreign partnership has one or more U.S. partners. The author further notes that the temporary regulations would treat a portion of the loan to the foreign partnership as a separate loan to a partner if the partnership makes a distribution to the partner that is funded by the CFC obligation. The article, published in the December 11, 2015, edition of Tax Management International Journal, is attached below. Document ID: 2016-0090 |
