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Analysis

Transition Tax Regs Seek To Clarify, Not Interpret, The Law

Law360 (August 3, 2018, 8:10 PM EDT) -- Proposed regulations for the federal tax overhaul’s repatriation tax don’t include any impactful statutory interpretations, but instead stick close to the law and earlier guidance when addressing foreign tax credits and other measurement issues, specialists say.

The U.S. Department of the Treasury on Wednesday released a 249-page document of proposed regulations for the tax code’s new Section 965, passed as part of the Tax Cuts and Jobs Act, which imposes a one-time transition tax on the accumulated earnings of U.S. multinationals’ foreign subsidiaries. The rules include guidance...
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