Overview
Tax Notes cited Steptoe’s Amanda Varma in an October 30 article titled “US Officials Explain Rationale Behind Partnership Subpart F Regulations.” The article discusses proposed regulations regarding the treatment of US property held by controlled foreign corporations in transactions involving partnerships.
On the aggregate approach the regulations use in determining whether the obligations of foreign partnerships constitute US property, Ms. Varma argues that the regulations could have taken an approach that examines whether there is a distribution to a US person with an actual income benefit, rather than a more indirect benefit.
The full article can be read at Tax Notes (subscription required).
