Collected Comments on Proposed Regs: Transition Tax
Collected Comments on Proposed Regs: Transition Tax
- Institutional AuthorsTax Analysts
- Code Sections
- Subject Area/Tax Topics
- Jurisdictions
- Tax Analysts Document Number2018-41408
- Tax Analysts Electronic Citation2018 TNT 203-14
The IRS has scheduled a public hearing for October 22 on proposed regulations (REG-104226-18) implementing section 965, which levies a transition tax on post-1986 untaxed foreign earnings of specified foreign corporations owned by U.S. shareholders by deeming those earnings to be repatriated.
Documents
The following documents are available from Tax Analysts:
Comments from Jones Day.
Comments from an individual.
Comments from New York State Bar Association Tax Section, October 5, 2018, letter and October 11, 2018, letter.
Comments from U.S. Chamber of Commerce.
Comments from American Citizens Abroad.
Comments from Baker McKenzie, October 5, 2018, letter and October 9, 2018, letter.
Comments from Abercrombie & Fitch.
Comments from National Association of Manufacturers.
Comments from National Foreign Trade Council.
Comments from Davis Polk & Wardwell LLP.
Comments from Deere & Co.
Comments from Roberts & Holland.
Comments from Tax Executives Institute Inc.
Comments from McDermott Will & Emery.
Comments from Phillips 66.
Comments from PWC, on behalf of Saltchuk Resources Inc.
Comments from Cargill Inc.
Comments from United States Council for International Business.
Comments from KPMG LLP.
Comments from Miller & Chevalier.
Comments from Silicon Valley Tax Directors Group.
Comments from Covington & Burling LLP.
Comments from FACT Coalition.
- Institutional AuthorsTax Analysts
- Code Sections
- Subject Area/Tax Topics
- Jurisdictions
- Tax Analysts Document Number2018-41408
- Tax Analysts Electronic Citation2018 TNT 203-14