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Final regulations under section 965; new version reflects changes

Final regulations under section 965; new version

The IRS has replaced on its website a version of the final regulations under section 965, and the new version reflects changes from the version released by the IRS on January 15, 2019.


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The new version of the final regulations delays the effective date for the section 965(h) election relating to “transfer agreements” until 30 days after the date when the final regulations are published in the Federal Register (rather than on January 31, 2019, as originally set forth in the January 15, 2019 version of the final regulations). This change means that taxpayers considering or in the process of filing transfer agreements now have at least an additional month of time.

Read a computer-generated document [PDF 904 KB] (an unofficial document produced by KPMG) that compares the version of the final regulations released on January 15, 2019, against the version of the final regulations that the IRS posted this week on its website. This document is intended to show what changes have been made to the final regulations. It has not been reviewed for accuracy. 

Refer to pages 94-95 and 267 of the document provided above.


During the partial government shutdown, the IRS and Treasury Department posted a version of the final regulations under section 965 on the IRS website. That version (January 15, 2019) of the final regulations under section 965 included the following statement:

This document will be submitted to the Office of the Federal Register (OFR) for publication. The version of the final rule released today may vary slightly from the published document if minor editorial changes are made during the OFR review process. The document published in the Federal Register will be the official document. 

The final regulations have not yet been released for publication in the Federal Register. According to the advance version released by the IRS, these regulations will be effective on the date when they are published in the Federal Register. 

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