H.R. 1865 and the Look-Through Treatment of Payments Between Related Controlled Foreign Corporations [Updated January 10, 2020] [open pdf - 393KB]
From the Document: "The House amendment to the Senate amendment to H.R. 1865, the Further Consolidated Appropriations Act, 2020, extended certain expiring provisions, including a number that were last extended through 2019 by the Consolidated Appropriations Act of 2016 (P.L. 114-113). This legislation was signed into law on December 20, 2019 (P.L. 116-94). Among these provisions are the look-through rules, which allow certain payments between related corporations to be excluded. The Joint Committee on Taxation estimates that extending the look-through rules for a year will cost $0.7 billion. The look-through rules were originally enacted in the Tax Increase Prevention and Reconciliation Act of 2005 (P.L. 109-222), for 2006 through 2008, and subsequently extended."
CRS In Focus, IF11392
Congressional Research Service: https://crsreports.congress.gov/