IRS Releases Guidance on Section 965
Posted on Apr 4, 2018 in International Tax, News
On April 2, 2018, the IRS issued Notice 2018-26, which describes additional regulations to be promulgated under Section 965. The regulations will provide anti-avoidance rules under the authority granted by the statute, provide an exception to the treatment of a foreign corporation as a specified foreign corporation (SFC) in connection with the downward attribution of stock through a partnership in certain circumstances; provide a proration rule for foreign income taxes in determining a SFC’s post-1986 earnings and profits as of November 2, 2017; and set out related reporting and documentation rules.
Read more here: Notice 2018-26