The U.S. IRS has announced that the Treasury Department and IRS intend to issue regulations that address issues arising from the enactment of the Tax Cuts and Jobs Act with respect to foreign corporations with previously taxed earnings and profits. --- Notice 2019-01 announces that the Treasury Department and the IRS intend to issue regulations addressing certain issues arising from the enactment of the Tax Cuts and Jobs Act, Pub. L. 115-97 (2017) on December 22, 2017, with respect to foreign corporations with previously taxed earnings and profits (“PTEP”). The notice describes regulations that the Treasury Department intend to issue...