Guidance on U.S. Transition Tax on Foreign Earnings
On 29 December 2017, the U.S. Treasury Department and the Internal Revenue Service issued Notice 2018-07, which provides guidance for computing the transition tax introduced under the Tax Cuts and Jobs Act.
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In general, newly enacted section 965 of the Internal Revenue Code imposes a transition tax on untaxed foreign earnings of foreign subsidiaries of U.S. companies by deeming those earni…
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