IRS Releases Guidance on the Transition Tax Provision
Last week, the IRS released Notice 2018-07 (the “Notice”), which provides guidance on calculating the so-called “transition tax” of the Tax Cuts and Jobs Act. While the Notice itself does not contain any specific regulations, it does describe the regulations that the IRS plans to issue at a later date, including guidance on the effects that the future regulations will have. The Notice also covers topics like the treatment of related-party transactions and hedging transactions, as well as the effective dates for the transition tax.
Read more: Notice 2018-07