IRS Reopens Door for Foreign Tax Profits Feedback
Published Date: 5/16/2025
Proposed Rule
Summary
Hey foreign corporations and their shareholders! The IRS is reopening the comment period on new rules about previously taxed earnings and profits, plus how to adjust your tax basis. If you’re involved, now’s your chance to weigh in before the deadline—these changes could impact your taxes and reporting.
Analyzed Economic Effects
1 provisions identified: 0 benefits, 0 costs, 1 mixed.
Rules on Previously Taxed Earnings
If you are a shareholder of a foreign corporation with previously taxed earnings and profits (PTEP), the IRS has proposed new rules about how those earnings are treated and how you adjust your tax basis. The proposal (REG-105479-18) was published December 2, 2024 and the IRS has reopened the comment period on it.
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Key Dates
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