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Long-awaited US proposed regulations address certain PTEP complexities

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United States

  • The Proposed Regulations would provide long-awaited updates to the previously taxed earnings and profits (PTEP) rules to address major legislative changes, including the enactment of IRC Sections 951A, 961(c), 965 and 986(c).
  • Tracking numerous PTEP accounts and associated attributes would impose a significant compliance burden on taxpayers.
  • Taxpayers will welcome favorable rules (1) providing "deriv…

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