Overview
Law360 and Tax Notes quoted Amanda Varma in articles discussing the repeal of the so-called downward attribution rule in Section 958(b)(4) (IRC § 958(b)(4)). The now-repealed section provided that a US person was not considered to own stock that was owned by a foreign person under the Subpart F constructive ownership rules.
Varma, who spoke on a panel during an international tax conference in Washington hosted by the Internal Revenue Service and the George Washington University Law School, said the repeal "drastically increases the number of controlled foreign corporations (CFCs) out there and is probably in the running for one of the most unexpected headaches arising from tax reform."
The full articles can be read at Law360 and Tax Notes (subscriptions required).