Long-awaited US proposed regulations address certain PTEP complexities
|Tax Alerts, Information Reporting, Trans ...|United States
The Proposed Regulations would provide long-awaited updates to the previously taxed earnings and profits (PTEP) rules to address major legislative changes, including the enactment of IRC Sections 951A, 961(c), 965 and 986(c).
Tracking numerous PTEP accounts and associated attributes would impose a significant compliance burden on taxpayers.
Taxpayers will welcome favorable rules (1) providing "derived basis" to partnerships holding CFC stock and (2) clarifying that IRC Section 961(c) basis applies…
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