Finally! Final Regulations Published for Section 965 Transition Tax

Written by , and

At long last, we have the first set of final regulations for the Tax Cuts and Jobs Act. Our International Tax Group celebrates with a look at how the Treasury and IRS have clarified Section 965 and why taxpayers may need to act quickly.

  • The de minimis threshold
  • Exceptions to the anti-abuse rules
  • Transfer agreements and the basis adjustment election

Read the full advisory here.