Overview
IRS Issues Additional Guidance Under Section 965: Notice 2018-13 announces that Treasury and the IRS intend to issue regulations for determining amounts included in gross income by a US shareholder by reason of section 965 as amended by the 2017 tax reform legislation (P.L. 115-97). The Notice describes regulations that the Treasury Department and the IRS intend to issue with respect to section 965 and a modification intended to be made regarding regulations described in section 3.03 of Notice 2018-07. The Notice also considers issues in connection with the repeal of section 958(b)(4) and announces the IRS’s intention to update the Instructions for Form 5471 as a result of such repeal. The Notice also describes the effective dates of the regulations and other guidance described.