Christine Hradsky No Comments

Foreign Taxation Technical Update: Section 965 Guidance

Summary

On October 1, the Department of the Treasury and the Internal Revenue Service (collectively, Treasury) issued Notice 2018-78 (the Notice). The Notice provides guidance with respect to the basis election under Prop. Reg. §1.965-2(f)(2), the application of rules for disregarding certain assets for determining aggregate foreign cash position in Prop. Reg. §1.965-3(b) to consolidated groups and relief in connection with Hurricane Florence. Read more

Christine Hradsky No Comments

International Tax Technical Update- April 2018

CHANGES IN SECTION 965 SPECIFIED FOREIGN CORPORATIONS’ TAX YEARS

Summary

On February 13, 2018, the Department of the Treasury and the Internal Revenue Service (collectively, “Treasury”) issued Rev. Proc. 2018-17 (the “Rev. Proc.”).  The Rev. Proc. provides additional guidance under Section 965, Treatment of deferred foreign income upon transition to participation exemption system of taxation, as amended by the “Tax Cut and Jobs Act,” which was enacted on December 22, 2017.  In particular, the Rev. Proc. provides guidance regarding certain changes in Section 965 specified foreign corporations’ tax years. Read more