Finance & markets · 29/10/2015

United States Property Held by Controlled Foreign Corporations in Transactions Involving Partnerships; Rents and Royalties Derived in the Active Conduct of a Trade or Business; Correction

The document corrects temporary regulations (TD 9733) published on September 2, 2015, regarding the treatment of property held by controlled foreign corporations in partnership transactions, and clarifies the treatment of rents and royalties in active business conduct.