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Proposed regulations issued on exclusion of previously taxed income of controlled foreign corporations

|Proposed Changes|United States
United States

The US Treasury Department and Internal Revenue Service (IRS) have issued proposed regulations with guidance on the exclusion from gross income of previously taxed income (PTI) of controlled foreign corporations (CFCs). The regulations were issued under Section 959 of the US Internal Revenue Code (IRC) and also address the related stock basis adjustments under Sec. 961.

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