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IRS, Treasury float rules on foreign earnings under tax reform

Tammy Whitehouse | August 2, 2018

The Internal Revenue Service and the U.S. Treasury Department have proposed regulations on how they envision implementing tax reform rules around repatriation of foreign earnings.

The proposed regulations focus on Section 965 of the Internal Revenue Code as amended by the Tax Cuts and Jobs Act, which will affect taxpayers that have ownership interest in certain foreign corporations. The tax reform measure signed into law in December 2017 ushered in significant change in corporate tax rules.

Under tax rules dating back to the 1980s, U.S. companies could escape U.S. federal income tax on earnings in foreign business operations if those earnings were held abroad for investment purposes. That gave companies an incentive to keep those earnings offshore. The Tax Cuts and Jobs Act...

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