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Transfer Pricing Report

Treasury On Course to Release Rules on Previously Taxed Income

Jan. 23, 2020, 5:32 PM

The Treasury Department is on track to release rules this spring on how companies should deal with previously taxed earnings and profits when calculating their U.S. taxes.

The rules will be proposed in the spring and, hopefully, finalized by the end of the year, James S. Wang, attorney-adviser at Treasury’s Office of Tax Policy, told Bloomberg Tax. An IRS official previously said the rules could come by June.

  • The Section 959 rules address how companies should order the different types of previously taxed income when filing their tax returns, and are meant to prevent double taxation of controlled...
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