Page 217 - International Taxation IRS Training Guides

Subpart
F Modifications (Cont'd)

 Repeal of
inclusion based on withdrawal of previously

F income from qualified investment
excluded subpart
of IRC 955)
(repeal

 Modification of stock attribution rules
to permit

downward attribution from
a foreign person to a US

person (repeal of
IRC 958(b)(4))

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