New Guidance Issued for Transition Tax on Deferred Foreign Earnings

Latham & Watkins LLP
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Anti-avoidance rules and limitations on application of the stock attribution rules among the topics to be addressed in forthcoming regulations.

Key Points -

..Certain transactions intended to reduce transition tax liability will be disregarded.

..Limitations imposed on downward attribution of stock from partners to partnerships.

..Reporting, election, and payment requirements clarified.

Please see full publication below for more information.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations. Attorney Advertising.

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