DEPARTMENT OF THE TREASURY Internal Revenue Service …

This document is scheduled to be published in the Federal Register on 01/25/2022 and available online at [4830-01-p] , and on DEPARTMENT OF THE TREASURY . Internal Revenue Service 26 CFR Part 1. [TD 9960]. RIN 1545-BP79. Guidance under Section 958 on Determining Stock Ownership AGENCY: Internal Revenue Service (IRS), TREASURY . ACTION: Final regulations . SUMMARY: This document contains final regulations regarding the treatment of domestic partnerships for purposes of determining amounts included in the gross income of their partners with respect to foreign corporations. The final regulations affect United States persons that own stock of foreign corporations through domestic partnerships and domestic partnerships that are United States shareholders of foreign corporations. DATES: Effective date: These regulations are effective on [INSERT DATE OF.]

951A regulations generally treat a domestic partnership as an aggregate of all of its partners for purposes of computing income inclusions under section 951A (and other provisions that apply by reference to section 951A). §1.951A-1(e)(1). That is, under the final section 951A regulations, partners do not take into account a distributive share of

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