IRS releases additional guidance on Section 965 transition tax

Tax Hot Topics newsletterThe IRS released additional guidance (Notice 2018-26) on April 2 covering the transition tax under Section 965 enacted by the Tax Cuts and Jobs Act. The guidance includes:

  • Limited penalty relief for estimated tax payments
  • Limited relief from the new controlled foreign corporation attributions rules
  • Guidance for stock sales and foreign taxes paid between measurement dates
  • Rules curbing transactions, entity classifications, and accounting method changes to reduce earnings and profits

Notice 2018-26 is the latest in a string of notices impacting the calculation of the Section 965 transition tax. For more information, read our Tax Flash.

David Sites
Washington National Tax Office
T +1 202 861 4104

David Zaiken
Managing Director,
Strategic Federal Tax Services
T +1 202 521 1543

Cory Perry
Tax – Exp. Manager,
Washington National Tax Office
T +1 202 521 1509

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