How Notice 2018-13 Frames Foreign Earnings Transition Tax
By Casey August, Barton Bassett and Peter Daub (February 1, 2018, 2:04 PM EST) -- On Jan. 19, the U.S. Department of the Treasury and the Internal Revenue Service issued Notice 2018-13 — Additional Guidance Under Section 965 and Guidance Under Sections 863 and 6038 in Connection with the Repeal of Section 958(b)(4). As its title implies, Notice 2018-13 elaborates on the first published guidance addressing the Tax Cuts and Jobs Act's new §965 deemed repatriation provision, which was issued on Dec. 29, 2017, as Notice 2018-07 (the prior notice). Notice 2018-13 also describes the IRS and Treasury's intent to issue updated Form 5471 instructions, which will introduce an important (and much needed) limitation to the filing requirements following the repeal of §958(b)(4)....
Law360 is on it, so you are, too.
A Law360 subscription puts you at the center of fast-moving legal issues, trends and developments so you can act with speed and confidence. Over 200 articles are published daily across more than 60 topics, industries, practice areas and jurisdictions.
