Treasury Confirms Issuance of Transition Tax Regulations by the End of the Year
Brenda Zendt, special adviser to the Treasury Office of International Tax Counsel, corroborated a prior report that the Treasury Department intends to issue final Section 965 regulations by the end of 2018. Treasury deputy assistant secretary for international tax affairs, Chip Harter, previously commented on the deadline while discussing Treasury’s goal to issue proposed regulations, within the next six weeks, for sections 163(j) interest limitation and 267A anti-hybrid rules, foreign tax credits, and for the base erosion and anti-abuse tax.
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