On 1 October 2018, the U.S. IRS issued Notice 2018-78, which provides an extension of the deadline for taxpayers to elect to make certain basis adjustments with respect to each deferred foreign income corporation and each E&P deficit foreign corporation in relation to the section 965 Transition Tax.
Under the proposed section 965 regulations (REG-104226-18), the deadline to make a basis adjustment election is the due date for the U.S. shareholder's return for the first taxable year tha…