On 15 January 2019, the U.S. IRS and Treasury Department issued the Regulations Regarding the Transition Tax Under Section 965 and Related Provisions, which contains the final regulations for the implementation of 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 o…