Earlier this month, the United States Treasury Department and the IRS issued proposed regulations under Section 965, as amended by the Tax Cuts and Jobs Act. These proposed regulations apply to the last tax year of a deferred foreign income corporation (DFIC) that begins before January 1, 2018, and will impact U.S. shareholders with direct or indirect interests in certain foreign corporations. While the proposed regulations do not substantially change the impact of the statutory language of Section 965, they do provide comprehensive rules and further guidance and clarification on numerous issues related to this one-time repatriation tax.

Our International Tax Practice will be hosting a webcast to answer your questions and help you better understand the intent and application of these proposed regulations.