Unintended CFC downward attributions get safe harbor.

The article reports that U.S. Internal Revenue Service (IRS) issued a revenue procedure on October 1, 2019 on U.S. persons who own stock in controlled foreign corporations (CFCs) may be able to benefit from safe harbors for determining CFC status and resulting income inclusions. It mentions foreign corporation owned by a foreign person can be attributed to a U.S. person under the downward attributions rules.