The IRS gives taxpayers a bit more direction on two provisions of the Tax Cuts and Jobs Act already in force. Our International Tax Group breaks down the new guidance for the repatriation tax and foreign partner withholding.
- Notice 2018-26 previews anti-avoidance and other rules under Section 965
- Notice 2018-29 moves ahead with withholding for non-publicly traded partnerships under Section 1446(f)
Read the full advisory here.