Repeal of the Limitation on Downward Attribution, Form 5471 and Safe Harbors from Rev Proc 2019-40
Update from the OBBB in 2025 The cross-border tax community was alarmed when section 958(b)(4) was repealed by the Tax Cuts and Jobs Act in December 2017. We were equally relieved in July 2025 when it was reinstated by the One Big Beautiful Bill Act (P.L. 119-21), along with the enactment of new […]


