Last week the IRS issued proposed regulations under the Section 965 Transition Tax. We have created charts of the 8 examples included in Prop. Treas. Reg. §1.965-1(g). The examples include: Example 1: Special Non-Attribution Rule For P'ships in Defining Specified Foreign Corporations Example 2: Attribution Rule For P'ships in Defining Specified Foreign Corporations Example 3: Determination of Accumulated Post-1986 Deferred Foreign Income (All E&P was PTI & DFI was zero) Example 4: Determination of Status... Read more →