Guidance on U.S. Transition Tax on Foreign Earnings

On 29 December 2017, the U.S. Treasury Department and the Internal Revenue Service issued Notice 2018-07, which provides guidance for computing the transition tax introduced under the Tax Cuts and Jobs Act.

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In general, newly enacted section 965 of the Internal Revenue Code imposes a transition tax on untaxed foreign earnings of foreign subsidiaries of U.S. companies by deeming those earnings to be repatriated. Foreign earnings held in the form of cash and cash equivalents are taxed at a…