Repeal of the Limitation on Downward Attribution: Three Years Later

Amanda Varma and Lauren Azebu co-authored an article titled "Repeal of the Limitation On Downward Attribution: Three Years Later" for Tax Notes International. This article examines the fallout of the repeal of section 958(b)(4), commonly referred to as a limitation on the downward attribution of stock ownership from foreign to US persons, three years after the tax reform (and four years after the repeal's effective date).