19 January 2018 Additional regulations forthcoming on computing TCJA transition tax The IRS has announced (Notice 2018-13) that it will issue additional regulations on computing the transition tax on untaxed foreign earnings of US controlled foreign companies (CFCs), which was enacted under the Tax Cuts and Jobs Act (TCJA). Notice 2018-13 also: — Modifies Notice 2018-7 (see Tax Alert 2017-2232), which announced forthcoming rules on determining the amount of cash and cash equivalents for purposes of applying the 15.5% rate and the amount of foreign earnings subject to the transition tax — Provides relief from "unintended regulatory and reporting consequences" resulting from the TCJA's modification of existing stock attribution rules Document ID: 2018-9005 |
