Treasury and IRS release second notice on toll tax

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January 2018

Overview

Today Treasury and the IRS released Notice 2018-13, signaling intent to issue regulations related to mandatory repatriation (the 'toll tax').  Notice 2018-13 is the second set of administrative guidance issued as part of the transition to a new territorial tax regime under the 2017 tax reform reconciliation act, also known as the ‘Tax Cuts and Jobs Act.’

Under the second set of guidance, Notice 2018-13 announces the intent to issue regulations for addressing the calculation of foreign earnings subject to the toll tax and other rules clarifying certain aspects of the new law.  Notice 2018-13 also makes a modification to Notice 2018-07 regarding the repatriation of earnings subject to the toll tax.  Finally, Notice 2018-13 provides taxpayers targeted relief from certain unintended regulatory and reporting consequences arising from a change to existing stock attribution rules in the recent tax legislation.

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Michael Urse

Partner, International Tax Services, PwC US

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