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How Notice 2018-13 Frames Foreign Earnings Transition Tax

Law360 (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...
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