AICPA Comments on CFC Look-Through Rule Guidance ...

For a partnership’s payment of rents or royalties, such payments will be attributed to a CFC partner under the similar principles embodied in reg. section 1.954-2(b)(5)(i)(B). In determining whether the CFC partner is related to the recipient CFC, reg. section 1.954-1(g)(1) would apply to test the CFC partner and the CFC payee. ................
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