MFA Comment Letter on Controlled Foreign Corporation (CFC) Attribution Rules

December 02, 2019

From: MFA

To:

Department of the Treasury
Internal Revenue Service

On December 2, MFA submitted a comment letter to the Department of Treasury and the IRS on their proposed rules designed to address unintended impacts on IRS rules as a result of the TCJA deletion of section 958(b)(4) of the Internal Revenue Code.  MFA’s letter supported the approach taken in the proposed rules and encouraged Treasury and the IRS to propose a similar modification to the rules under section 1248 of the Code because the deemed dividend provisions in that section could unfairly increase taxes for U.S. partnerships following the repeal of 958(b)(4).  MFA also supported the safe harbor in related Revenue Procedure 2019-40, which allows U.S. persons to make CFC determinations based on information the U.S. person knows or that is available in public reports.

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