Download This PaperThe Proposed 'Downward Attribution' Regulations and Revenue Procedure
16 Pages Posted: 1 Dec 2019
Date Written: November 15, 2019
Abstract
This paper summarizes the proposed regulations and Revenue Procedure that was issued on October 2, 2019 and provides guidance on issues that have arisen as a result of the repeal of section 958(b)(4) of the Internal Revenue Code.
Keywords: tax, 958(b)(4), downward attribution
JEL Classification: H20
Suggested Citation: Suggested Citation
Miller, David S. and Webb, Sean, The Proposed 'Downward Attribution' Regulations and Revenue Procedure (November 15, 2019). Available at SSRN: https://ssrn.com/abstract=3488042 or http://dx.doi.org/10.2139/ssrn.3488042
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