The U.S. IRS has published Guidance Regarding the Transition Tax Under Section 965 and Related Provisions, which contains the proposed regulations implementing section 965 of the Internal Revenue Code as amended by the Tax Cuts and Jobs Act.
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WASHINGTON−The Internal Revenue Service and the Department of the Treasury today issued proposed regulations on section 965 of the Internal Revenue Code. The proposed regulations affect United States shareholders, as defined under section 951(b) o…