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U.S. IRS Issues Corrections to Final Transition Tax Regs

11 April 2019

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Approved Changes

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United States

On 10 April 2019, two correction documents to the final transition tax regulations (TD 9846) were published in the Federal Register. The first correction document generally provides clarifying amendments, including in relation to the dealer exclusion for specific commodities, the treatment of a distribution by a specified foreign corporation to another specified foreign corporation made before 1 January 2018, the limited-basis election, and the anti-diminution rule. The second correction document confirms that although the final transition tax regulations are considered a "major rule" for purposes of the Congressional Review Act (CRA), the standard that major rules take effect 60 days...