The U.S. Treasury Department and IRS today posted a version of the final regulations concerning the transition tax under section 965 on the IRS website.
The final regulations [PDF 1.19 MB] (305 pages) finalize regulations that were proposed in August 2018. The preamble states that the final regulations retain the basic approach and structure of the proposed regulations with certain revisions. The final regulations will be effective on the date when they are published in the Federal Register.
The version of the regulations posted on the IRS website includes 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 purpose of this report is to provide text of the final regulations. Analysis of these regulations will be provided in a future report from KPMG.
The KPMG logo and name are trademarks of KPMG International. KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever. The information contained in herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.