Treasury Department Releases Notice 2018-13, Providing Additional Guidance on Section 965
Posted on Jan 22, 2018 in International Tax, News
The IRS and Treasury Department have issued additional guidance regarding the transition tax imposed by the tax law’s new section 965. In addition to providing background information on section 965, Notice 2018-13 states that future regulations will be introduced to address: factors for determining a specified foreign corporation; an alternative method for calculating post-1986 earnings and profits; the treatment of deficits; the determination of aggregate foreign cash position; and currency translation rules. Additionally, the notice requests comments, provides effective dates, and offers guidance with regards to the repeal of section 958(b)(4).