Treasury Intends to Finalize All Major TCJA Guidance by October 1
Speaking at a conference yesterday, Chip Harter, Treasury deputy assistant secretary for international tax affairs, stated that he is “fairly confident” that Treasury will be able to finalize all major guidance related to the Tax Cuts and Jobs Act by October 1st of this year. With respect to timing, Harter stated that he expects that regulations under section 901(m) will be released “any day now,” and that proposed and final anti-hybrid regulations will be released in the next couple of weeks. Additionally, Harter expects that proposed and final regulations under section 163(j) (limitation on the deductibility of interest) will be released in March and that regulations under sections 250 (foreign-derived intangible income) and 951A (global intangible low-taxed income) will be released this spring and summer, respectively.
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