02 April 2018 IRS publishes additional Section 965 guidance The IRS has issued Notice 2018-26, providing additional guidance under Section 965. Specifically, the IRS describes regulations that it intends to issue in connection with the transition tax on the untaxed foreign earnings of foreign subsidiaries of US shareholders under Section 965 enacted by the Tax Cuts and Jobs Act (TCJA), P.L. 115-97. The described regulations include: (1) anti-avoidance rules for certain transactions, accounting method changes and elections that occurred (or were made) on or after November 2, 2017; (2) guidance on certain elections; and (3) procedures on reporting and paying the tax. The Notice also includes relief from certain estimated tax requirements and penalties resulting from the transition tax and TCJA changes to stock attribution rules. A Tax Alert is forthcoming. Document ID: 2018-9007 |
