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House Passes Retroactive Technical Correction to Plug §954(c)(6) Loop-Hole. Taxpayers benefiting from the subpart F “look-through” rule of §954(c)(6), enacted in May as part of the Tax Increase Prevention and Reconciliation Act (TIPRA) (commonly referred to as the “TIPRA look-through rule”), should be aware that some of the protection it affords from subpart F will be retroactively eliminated if a technical correction that the U.S. House of Representatives approved on July 29 is ultimately enacted. We believe it is likely that the technical correction will be enacted on a retroactive basis.
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