The US IRS today issued an advance copy of Notice 2018-13, providing guidance on the transition tax on foreign earnings of foreign subsidiaries of US companies called for under the newly enacted Tax Cuts and Jobs Act.
The notice, to be published in IRB 2018-06 on February 5, describes regulations that the Treasury Department and the IRS intend to issue, including rules addressing the calculation of earnings under the transition tax and other rules to clarify certain aspects of the law.
The notice also makes a modification to Notice 2018-07 issued on Dec. 29, 2017, regarding the repatriation of earnings subject to the transition tax.
The notice further provides taxpayers targeted relief from certain unintended regulatory and reporting consequences arising from a change to existing stock attribution rules in the recent tax legislation.
Treasury and the IRS request comments on the rules described in the notice and on what additional guidance should be issued to assist taxpayers in computing the transition tax.
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