2018-08-09
Last week the IRS issued proposed regulations under the Section 965 Transition Tax. We have created charts of the 8 examples included in Prop. Treas. Reg. §1.965-1(g). The examples include:
Example 6 is helpful in that it shows how to allocate deficits when a U.S. shareholder has some CFCs with deficits and others with positive earnings.
All 1,000+ charts on andrewmitchel.com can be viewed in topical order here or alpha-numeric order here.