Look-through Rule under I.R.C. Section 954(c)(6) Is Extended

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The President signed The Tax Increase Prevention Act of 2014 on December 19, 2014. The new Public Law No. 113-295 (H.R. 5771) retroactively extended various tax provisions that had expired as of December 31, 2013. A U.S. international tax provision under I.R.C. Section 954(c)(6) was extended for the year 2014 through December 31, 2014. This provision is a look-through rule which provides some relief from the anti-deferral regime of Subpart F for U.S. shareholders of controlled foreign corporations (“CFCs”). A controlled foreign corporation is a foreign corporation of which more than 50% of the vote or …read more

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