OIRA Receives Final Transition Tax Regulations for Review
On December 6, the Office of Information and Regulatory Affairs (OIRA) received final regulations under section 965, the so-called transition tax. OIRA will have 45 days to review the regulations, as they are not designated for expedited review. The Treasury Department has previously stated that the final regulations will provide additional detail regarding ordering rules for determining earnings and profits, but the final regulations may include other changes to the proposed regulations as well. The final regulations are expected to be released by the end of the calendar year.