A notice from the U.S. IRS has been published in the Federal Register announcing that a public hearing will be held on 22 October 2018 on the proposed regulations (REG-104226-18) relating to section 965 of the Internal Revenue Code as amended by the Tax Cuts and Jobs Act. Section 965 concerns the transition tax that provides for the inclusion of the pro-rata share of the post-1986 deferred foreign earnings taxed at a rate of 15.5% on foreign earnings held in the form of cash and cash equival…