Show simple item record Fisher, Emi en 2022-01-21T21:43:18Z 2022-01-21T21:43:18Z 2021 en
dc.identifier.citation Fisher, Emi. (2021). Unintended consequences of the repeal of §958(b)(4) and proposed solutions. Tax Development Journal, Vol. 11, pages 1 - 15. en
dc.description.abstract The Tax Cuts and Jobs Act of 2017 repealed §958(b)(4) (the Repeal), which prevented a U.S. person from constructively owning stock owned by a non-U.S. person in determining if a corporation is a controlled foreign corporation (CFC). After the Repeal, a U.S. corporation owned by a foreign corporation is considered to own stock in a foreign affiliate owned by the foreign parent. Thus, the foreign affiliate can be considered a CFC of the U.S. subsidiary even if the U.S. subsidiary does not own directly or indirectly any shares in the foreign affiliate. These changes caused unintended negative consequences for foreign multinational corporations with U.S. subsidiaries. Even though some measures have been taken to mitigate these consequences, issues remain. This article discusses problems caused by the Repeal that affect foreign corporations with U.S. subsidiaries and proposes solutions. en
dc.format application/pdf en
dc.format.extent 15 pages en
dc.language.iso en en
dc.publisher California State University, Northridge en
dc.relation.uri en
dc.rights Copyright 2021 by the authors and California State University, Northridge en
dc.subject The Tax Cuts and Jobs Act of 2017 en
dc.subject Taxation en
dc.subject Controlled foreign corporation (CFC) en
dc.title Unintended consequences of the repeal of § 958(b)(4) and proposed solutions en
dc.type Article en

Files in this item


This item appears in the following Collection(s)

Show simple item record

Search DSpace

My Account

RSS Feeds