The U.S. IRS and Treasury have issued the final regulations Single-Entity Treatment of Consolidated Groups for Specific Purposes (T.D. 9973), which were published in the Federal Register on 23 February 2023. The final regulations concern the treatment of the members of a consolidated group as a single U.S. shareholder for the purpose of applying section 951(a)(2)(B) with respect to CFC-to-CFC distributions of previously taxed earnings and profits (PTEP) under section 959(b) (section 959(b) d…