The Proposed 'Downward Attribution' Regulations and Revenue Procedure
16 Pages Posted: 1 Dec 2019
Date Written: November 15, 2019
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