Treasury releases final Section 965 regulations

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January 2019

Today, Treasury released final regulations under amended Section 965 (‘the toll charge’) and submitted them for publication in the Federal Register. The final 965 regulations provide guidance relating to the toll charge due upon the mandatory deemed repatriation of certain deferred foreign earnings. On August 1, 2018, Treasury previously released proposed regulations under Section 965 as amended by the 2017 tax reform legislation.

The regulations contain 145 pages of preamble language and 160 of regulatory text, including 37 examples. The final regulations contain effective dates that are tied to the date of publication in the Federal Register.

PwC will publish a detailed analysis of the final regulations within the coming days.  In addition, we will discuss the latest toll charge guidance in a Tax Reform Readiness Series webcast (registration available soon).

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Doug McHoney

International Tax Services Co-Leader, PwC US

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