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Final regulations govern Sec. 965 transition tax

January 16, 2019

The IRS finalized regulations on Wednesday on the Sec. 965 transition tax, which was added to the Code by the law known as the Tax Cuts and Jobs Act, P.L. 115-97. Sec. 965 applies to the last tax year of a deferred foreign income corporation (DFIC) that begins before Jan. 1, 2018. The Subpart F inco...