The IRS has provided additional foreign earnings transition tax guidance. The IRS first issued guidance for computing the “transition tax” on the untaxed foreign earnings of U.S. companies’ foreign subsidiaries in Notice 2018-7, I.R.B. 2018-4, 317. The transition tax was enacted as part of the Tax Cuts and Jobs Act (Act) (P.L. 115-97). In addition, […]
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