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01 August 2018

IRS issues Section 965 transition tax regulations

On August 1, 2018, the IRS and US Treasury Department issued proposed regulations on the one-time transition tax under Section 965 on untaxed foreign earnings of US controlled foreign companies, which was enacted under the Tax Cuts and Jobs Act. The much-anticipated regulations follow three notices (Notice 2018-07, Notice 2018-13, and Notice 2018-26. Tax Alerts and webcast details are forthcoming.

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ATTACHMENT

Section 965 Proposed Regulations

Document ID: 2018-9015

 

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