Paul Schmidt Comments on "Downward Attribution" Glitch in New Tax Law

News / July 10, 2018

Partner Paul Schmidt is quoted in an article published in Bloomberg’s “Daily Tax Report” on July 5, 2018. The article, “Unintended Tax Glitch Could Hit Multinationals, Private Equity,” reports on concerns about a provision of the new tax law that repealed a limitation on the application of certain attribution rules that could cause foreign entities to be treated as controlled foreign corporations for U.S. tax purposes. Although there appears to be Congressional intent for certain exceptions to apply, no such exceptions were actually included in the statute.