Name
International Taxation: OBBBA Implementing Guidance, Part 2 (Sections 250, 951B, 904(b)(6), 163(j)): Meet the New Issues, Same as the Old Issues
Date & Time
Wednesday, January 13, 2027, 10:30 AM - 11:45 AM
Description

Part two picks up Sections 250, 951B, 904(b)(6), and 163(j): the reworked Section 250 deduction, the new foreign-controlled-CFC rules that backfill the restored downward-attribution limit, the added FTC-limitation coordination, and the interest-limitation interactions that feel familiar for a reason.