OIRA Receives Proposed and Final Regulations under Section 168(k)
Posted on Jul 29, 2019 in Uncategorized
On July 25, 2019, the Department of Treasury and the Internal Revenue Service submitted final and proposed regulations under section 168(k) to OIRA (the Office of Information and Regulatory Affairs), which is part of the OMB (Office of Management and Budget). Amended by the Tax Cuts and Jobs Act, section 168(k) generally allows full expensing of certain depreciable property. The...
IRS Official States that Final Foreign Tax Credit Regulations Likely to Be Released by Fall and BEAT Regulations Likely to Be Released Before the End of the Year
Posted on Jul 17, 2019 in International Tax
At an event for the National Association for Business Economics on July 16, Peg O’Connor (deputy associate chief counsel (Operations and International Programs) at the IRS Office of the Associate Chief Counsel, International) stated that she expects final regulations addressing foreign tax credits to be released by the end of the summer and final regulations under section 59A (Base...
IRS Provides Additional Q&A Guidance on Section 965
Posted on Jul 16, 2019 in International Tax
On July 16, 2019, the IRS released additional guidance in a Q&A format with respect to section 965. Enacted by the Tax Cuts and Jobs Act, section 965 generally imposes a transition tax on a US shareholder’s pro rata share of the accumulated earnings and profits of certain foreign corporations. The guidance includes information on making subsequent installment payments and filing...