Here Come the Regulations: Treasury Releases Proposed Regulations on Repatriation Tax

    View Authors August 2018

    The US Treasury and the IRS have issued proposed regulations under Section 965 of the Tax Code providing key guidance on the one-time tax on offshore earnings. This new guidance on the so-called “repatriation tax” or “transition tax” generally follows the interim and prior guidance issued over the last several months with some modifications and expansions. The Proposed Regulations now enter the public comment period.

    This update provides an overview of the key issues addressed in the Proposed Regulations, identifies those items on which the Treasury has invited further comment, and details what we should expect next from Washington DC for potential tax legislation and upcoming regulations.