The Internal Revenue Service (IRS) has just released final
regulations regarding the treatment of United States property held
by a controlled foreign corporation (CFC) in connection with
certain transactions involving partnerships. The final regulations
also provide rules for determining whether a CFC is considered to
derive rents and royalties in the active conduct of a trade or
business for purposes of determining foreign personal holding
company income, as well as rules for determining whether a CFC
holds United States property as a result of certain related party
factoring transactions. The new rules finalize proposed
regulations, and withdraws temporary regulations, published on
September 2, 2015. It also finalizes proposed regulations, and
withdraws temporary regulations, published on June 14, 1988. In
addition, the IRS has issued proposed regulations that provide
rules regarding the determination of the amount of United States
property treated as held by a CFC
