Treasury and the IRS released a package of proposed regulations (REG-104226-18
) on Aug. 2 under Sections 965, 962 and 986(c). The package offers limited relief for taxpayers, and largely adopts guidance issued in previous notices. Although the proposed regulations do not meaningfully change the overall landscape of the Section 965 repatriation tax, the guidance provides comprehensive rules as well as examples covering numerous issues related to this one-time transition tax.
The proposed regulations are the first issued under Section 965, and are the latest development in the government’s ongoing series of releases on the subject since the signing of P.L. 115-97 (commonly referred to as the Tax Cuts and Jobs Act) on Dec. 22, 2017.
A substantial portion of the package adopts rules announced in prior notices. However, the proposed regulations do include some welcome new guidance and clarifications previously absent.
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