The US IRS this week announced that in some cases where individuals temporarily conduct activities in a foreign country as a result of the COVID-19 emergency, the activity will not give rise to a foreign branch separate unit for purposes of the Section 1503(d) dual consolidated loss rules or an obligation to file Form 8858 (“Information Return of U.S. Persons With Respect to Foreign Disregarded Entities (FDEs) and Foreign Branches (FBs)”).
Details of the new policy are provided in Rev. Proc. 2020-30, published in Internal Revenue Bulletin: 2020-22.
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