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. The regulations provide guidance on the exclusion from gross income for US shareholders of CFCs for distributions of earnings and profits of the CFC that are attributable to amounts which are, or have been, included in a US shareholder's gross income under Sec. 951(a)....