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One Big Beautiful Bill Act (OBBBA) - No More Uncontrolled Downward Attribution?
When the Tax Cuts and Jobs Act (TCJA) repealed section 958(b)(4) back in 2017, it unleashed chaos across the cross-border tax landscape. The repeal allowed downward attribution from foreign to U.S. persons — causing hundreds of unintended Controlled Foreign Corporation (CFC) classifications and widespread compliance headaches.Now, with the One Big Beautiful Bill Act (OBBBA) of 2025, section 958(b)(4) is finally restored — and a new section 951B introduced — providing a more surgical fix for the original “de-control” problem Congress had aimed to solve.This episode explores what’s changed…
The skinny
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