February 22, 2023
IRS finalizes regulations treating consolidated group members as single US shareholder
The IRS has issued final regulations (TD 9973) that treat consolidated group members as a single US shareholder in certain cases for purposes of IRC Section 951(a)(2)(B). The final regulations affect consolidated groups that own stock in foreign corporations. For background on the proposed regulations, see Tax Alert 2022-1933. A Tax Alert is forthcoming.
Published by NTD’s Tax Technical Knowledge Services group; Carolyn Wright, legal editor