Collected Comments on Proposed Regs: Transition Tax

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.