The IRS on December 14, 2018, released an advance version of Notice 2019-01 that provides guidance on the treatment of “previously taxed earnings and profits” or PTEP (colloquially referred to as PTI).
Notice 2019-01 [PDF 85 KB] announces that Treasury and the IRS intend to issue proposed regulations under sections 959 and 961 that will take into account various changes made by the new U.S. tax law (Pub. L. No. 115-97), and will withdraw the existing proposed regulations.
Read a December 2018 report [PDF 53 KB] prepared by KPMG LLP