On November 3, 2016, the Treasury issued final regulations (T.D. 9792) that set forth guidance on when a controlled foreign corporation (CFC) has a deemed repatriation under Section 956 in connection with transactions involving partnerships. These final regulations largely adopt temporary and proposed regulations issued in September 2015. The changes made by the final regulations were generally not substantive but rather are primarily intended to address the clarity and administration of the rules.
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