dockets: IRS-2018-0041

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id agency_id title docket_type last_modified object_id rin dkabstract category subtype keywords program short_title effective_date organization attrs_raw attr_source
IRS-2018-0041 IRS Foreign Corporations: Previously Taxed Earnings and Profits (PTEP) (Notice 2019-01) Nonrulemaking 2021-11-16T12:16:41Z 0b0000648398047e   This notice announces that the Department of the Treasury (“Treasury Department”) and the Internal Revenue Service (“IRS”) intend to issue regulations addressing certain issues arising from the enactment of the Tax Cuts and Jobs Act, Pub. L. 115-97 (2017) (the “Act”), on December 22, 2017, with respect to foreign corporations with previously taxed earnings and profits (“PTEP”). Section 2 of this notice provides background on section 959 of the Internal Revenue Code (“Code”) and other relevant Code provisions. Section 3 of this notice describes proposed regulations that the Treasury Department and the IRS intend to issue concerning PTEP arising under provisions of the Act (the “forthcoming regulations”). Section 4 of this notice describes the proposed applicability date of the forthcoming regulations. Section 5 of this notice requests comments and provides contact information; as explained in that section, the Treasury Department and the IRS intend to address additional PTEP issues in separate guidance.     ["Income taxes"]       CC:INTL {"displayProperties": [{"name": "organization", "label": "Organization", "tooltip": "Identifies docket's (a regulatory action) orginating agency and/or department, equivalents: Division, Pre-EDOCKET ID."}, {"name": "abstract", "label": "Description", "tooltip": "Describes an agency's specific regulatory action; equivalents: Abstract, Docket Subject, General Info, Related To, Summary."}], "keywords": ["Income taxes"], "modifyDate": "2021-11-16T12:16:41Z", "dkAbstract": "This notice announces that the Department of the Treasury (\u201cTreasury Department\u201d) and the Internal Revenue Service (\u201cIRS\u201d) intend to issue regulations addressing certain issues arising from the enactment of the Tax Cuts and Jobs Act, Pub. L. 115-97 (2017) (the \u201cAct\u201d), on December 22, 2017, with respect to foreign corporations with previously taxed earnings and profits (\u201cPTEP\u201d). Section 2 of this notice provides background on section 959 of the Internal Revenue Code (\u201cCode\u201d) and other relevant Code provisions. Section 3 of this notice describes proposed regulations that the Treasury Department and the IRS intend to issue concerning PTEP arising under provisions of the Act (the \u201cforthcoming regulations\u201d). Section 4 of this notice describes the proposed applicability date of the forthcoming regulations. Section 5 of this notice requests comments and provides contact information; as explained in that section, the Treasury Department and the IRS intend to address additional PTEP issues in separate guidance.", "agencyId": "IRS", "program": null, "shortTitle": null, "subType2": null, "title": "Foreign Corporations: Previously Taxed Earnings and Profits (PTEP) (Notice 2019-01)", "generic": null, "field1": null, "docketType": "Nonrulemaking", "petitionNbr": null, "rin": null, "organization": "CC:INTL", "legacyId": null, "subType": null, "category": null, "field2": null, "effectiveDate": null, "objectId": "0b0000648398047e"} single_get

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