N-2019-01: Previously Taxed Earnings and Profits Accounts

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IRS GuideWire December 14, 2018

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Issue Number:    N-2019-01

Inside This Issue

Notice 2019-01 announces that the Treasury Department and the IRS intend to issue regulations addressing certain issues arising from the enactment of the Tax Cuts and Jobs Act, Pub. L. 115-97 (2017) on December 22, 2017, with respect to foreign corporations with previously taxed earnings and profits (“PTEP”).  The notice describes regulations that the Treasury Department intend to issue including (i) rules relating to the maintenance of PTEP in annual accounts and within certain groups; (ii) rules relating to the ordering of PTEP upon distribution and reclassification; and (iii) rules relating to the adjustment required when an income inclusion exceeds the earnings and profits of a foreign corporation.  It is anticipated that the regulations announced in the notice will apply to taxable years of U.S. shareholders ending after the date of release of the notice and to taxable years of foreign corporations ending with or within such taxable years.

Notice 2019-01 will be in IRB: 2019-03, dated 1/14/2019.

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