The U.S. IRS and Treasury have issued a notice on the withdrawal of proposed regulations on the Exclusion from Gross Income of Previously Taxed Earnings and Profits, and Adjustments to Basis of Stock in Controlled Foreign Corporations and of Other Property, which were first issued in 2006. The proposed regulations provided guidance relating to the exclusion from gross income of previously taxed earnings and profits under section 959 of the Internal Revenue Code (Code) and related basis adjustments under section 961 of the Code, but were never finalized. The proposed regulations are withdrawn to help prevent possible abuse or other...