IRS Floats Rules For Transition Tax On Foreign Earnings

Law360 (August 1, 2018, 11:57 AM EDT) -- The U.S. Department of Treasury dashed many corporate taxpayers’ hopes on Wednesday, nixing suggested exceptions or potential areas for wiggle room in regulations to determine how to impose a one-time transition tax on the accumulated earnings of U.S. multinationals’ foreign subsidiaries as part of 2017’s federal tax overhaul.

The proposed rules cover Section 965 of the tax code, which deems some earnings of foreign subsidiaries as repatriated and taxes them at dual rates. (AP) The eagerly awaited proposed regulations include guidance on how to measure the foreign cash position of U.S. companies, as part of the tax code’s new Section 965, passed as part of...

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