October 11 2018

Additional guidance announced for transition tax on foreign earnings

Source: IBFD Tax Research Platform News

On 10 October 2018, the US Treasury Department and the US Internal Revenue Service (IRS) issued a document (2018-22022) to announce the availability of additional guidance regarding the transition tax under section 965 of the US Internal Revenue Code (IRC), issued as IRS Notice 2018-78.

On 9 August 2018, the Treasury Department and the IRS published in the Federal Register proposed regulations (REG-104226-18) under IRC section 965.

On 1 October 2018, the Treasury Department and the IRS issued Notice 2018-78, which contained additional guidance related to IRC section 965 and the proposed regulations.

Notice 2018-78 was issued in advance of final regulations due to the imminent filing deadlines that could otherwise apply to the forms and elections described therein.