This document contains proposed regulations implementing section 965 of the Internal Revenue Code (``Code'') as amended by the Tax Cuts and Jobs Act, which was enacted on December 22, 2017. The proposed regulations would affect United States persons with direct or indirect ownership interests in certain foreign corporations.
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Guidance Regarding the Transition Tax Under Section 965 and Related Provisions
This document contains proposed regulations implementing section 965 of the Internal Revenue Code (``Code'') as amended by the Tax Cuts and Jobs Act, which was enacted on Decemb...
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83 FR 39514
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“Guidance Regarding the Transition Tax Under Section 965 and Related Provisions,” thefederalregister.org (August 9, 2018), https://thefederalregister.org/documents/2018-16476/guidance-regarding-the-transition-tax-under-section-965-and-related-provisions.