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Additional Guidance Under Section 965 and …

Additional Guidance Under Section 965 and Guidance Under Sections 863 and 6038 in Connection with the Repeal of Section 958(b)(4) Notice 2018-13 Section 1. OVERVIEW This notice announces that the Department of the Treasury ( Treasury Department ) and the Internal Revenue Service ( IRS ) intend to issue regulations for determining amounts included in gross income by a United States shareholder Under Section 951(a)(1) by reason of Section 965 of the Internal Revenue Code ( Code ) as amended by An Act to provide for reconciliation pursuant to titles II and V of the concurrent resolution on the budget for fiscal year 2018, 115-97 (the Act ), which was enacted on December 22, 2017.

.02 Determination of United States Shareholder’s Section 951(a)(1) Inclusion By Reason of Section 965 Section 965(b)(1) provides that, if …

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