Andrew Mitchel LLC

International Tax Blog - New and Interesting International Tax Issues

23 New Charts - Code §956 Regulation Examples from T.D. 9792


Last month, the IRS released Treasury Decision 9792, which included final regulations under Code §956.  The final regulations include rules regarding U.S. property held by controlled foreign corporations ("CFCs") in transactions involving partnerships.  There were 23 examples in the regulations, and we have created new situational charts that illustrate all 23 of the examples. 

The charts are available at, where you can find hundreds of other situational charts. 

Tags: 956 Investments in U.S. Property, Authority - Treasury Decisions, Charts - Situational Charts