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