Share with your friends

Proposed regulations: Amount determined under section 956 for corporate U.S. shareholders

U.S. tax law, section 956 on CFCs

The U.S. Treasury Department and IRS today released proposed regulations (REG-114540-18) concerning the amount determined under section 956 for corporate United States shareholders.


Related content

The proposed regulations [PDF 108 KB] reduce the amount determined under section 956 with respect to certain domestic corporations that own (or are treated as owning) stock in controlled foreign corporations (CFCs).

As briefly explained in a related IRS release—IR-2018-210—the proposed regulations reflect changes made by the new U.S. tax law (Pub. L. No. 115-97, enacted December 22, 2017).

The new tax law added a participation exemption system for the taxation of certain foreign income. Today’s proposed regulations are intended to provide that the application of section 956 is consistent with the new participation exemption system.

The proposed regulations are pending release for publication in the Federal Register.

The purpose of this report is to provide text of the proposed regulations. A discussion of initial impressions about these proposed regulations will be provided in a future report from KPMG.

The KPMG logo and name are trademarks of KPMG International. KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever. The information contained in herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.

Connect with us


Want to do business with KPMG?


loading image Request for proposal