Transcription of Additional Guidance Under Section 965 and …
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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. See Notice 2018-07, 2018-4 317, for prior Guidance issued Under Section 965. In addition, this notice provides Guidance in connection with the repeal of Section 958(b)(4) by the Act. Section 2 of this notice provides background on Section 965 and the repeal of Section 958(b)(4) by the Act.
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
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