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IRS Publishes Guidance For Handling Transition Tax

Law360, New York (January 2, 2018, 3:30 PM EST) -- The IRS has published guidance aimed at helping taxpayers determine foreign earnings and profits under the transition tax provision of the recently passed Republican tax overhaul, including what to do when a U.S. shareholder controls foreign corporations with multiple inclusion years.

The transition tax, which has repatriation rates of 15.5 percent for cash and 8 percent for noncash income, is part of the sweeping tax code changes under the GOP’s $1.5 trillion tax cut bill. After President Donald Trump signed H.R. 1, formerly known as the...
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