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IRS Gets Heat for Mulling Unwind of Gap-Year Transactions

Nov. 22, 2019, 10:48 PM

The IRS is getting pushback for considering allowing companies to reverse transactions that occurred during a gap in the effective dates of two international tax provisions.

The transactions would have occurred between Jan. 1, 2018, and Nov. 30, 2018, after the tax law’s Section 965 repatriation tax calculations and before the effective date of the tax on global intangible low-taxed income.

The change would be incredibly complex, two speakers told the IRS at a Nov. 22 hearing on the Section 245A regulations. The rules allow for domestic companies to take a 100% deduction on the foreign-source portion of dividends received from...

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