Multinationals can limit the effect of a pivotal tax rule repeal
While Section 958 downward attribution rules can result in significant CFC stock reporting obligations, there are some steps businesses can take to limit their impact. In Bloomberg Tax, our international tax partners break down the effects of these rules.

There are steps businesses can take if they’re subject to downward attribution in years for which they’ve already filed returns, or if they’re planning new investment structures to prevent downward attribution and the triggering of controlled foreign corporation stock reporting requirements.
To determine whether they’re subject to downward attribution, multinationals should review the entire global structure of parents and subsidiaries; identify the full legal ownership of the entire structure, with a focus on the tax residency of the upper-tier investors; and evaluate the structures in the lower tiers to see if they meet the requirements for attribution.