On 2 April 2018, the U.S. IRS announced the release of new guidance on computing the transition tax on foreign earnings, business interest expense limitations, and withholding on the transfer of partnership interests by foreign persons. --- Additional Guidance on Transition Tax on Foreign Earnings The Treasury Department and the Internal Revenue Service today provided additional guidance (Notice 2018-26) for computing the "transition tax" on the untaxed foreign earnings of foreign subsidiaries of U.S. companies under the Tax Cuts and Jobs Act enacted on Dec. 22, 2017. The Treasury Department and the IRS provided prior guidance on the transition tax...