The US IRS on November 19 published final regulations on the attribution of ownership of stock or other interests for purposes of determining whether a person is a related person with respect to a controlled foreign corporation (CFC) under section 954(d)(3).
The regulations, effective today, finalize proposed regulations issued on May 20 without change. No comments were received on the proposed version of the regulations.
The regulations limit the application of section 318(a)(3) constructive ownership rules for purposes of the definition of related person in section 954(d)(3) to avoid inappropriately treating entities, including CFCs, that do not have a significant relationship to each other as related persons.
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