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September 1, 2020

IRS to issue regulations addressing S corporations with accumulated E&P

The IRS has announced (Notice 2020-69) its intent to issue regulations addressing how IRC Sections 951 and 951A apply to certain S corporations with accumulated earnings and profits (E&P). The regulations will also address the treatment of qualified improvement property under IRC Section 168(g)'s alternative depreciation system for purposes of calculating qualified business asset investment under the foreign-derived intangible income (FDII) and global intangible low-taxed income (GILTI) provisions. A Tax Alert is forthcoming.