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On 19 January 2017, the U.S. IRS announced the issuance of additional guidance on the transaction tax on foreign earnings --- WASHINGTON - The Treasury Department and the Internal Revenue Service (IRS) today provided additional guidance (Notice 2018-13) for computing the “transition tax” on the untaxed foreign earnings of foreign subsidiaries of U.S. companies under the Tax Cuts and Jobs Act. On Dec. 29, 2017, the Treasury Department and the IRS provided initial guidance on computing the transition tax in Notice 2018-07. Today’s notice describes regulations that the Treasury Department and the IRS intend to issue, including rules addressing the...