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OIRA review completed, final regulations under section 965 transition tax

U.S. final regulations

OMB’s Office of Information and Regulatory Affairs (OIRA) today completed its review of Treasury Department final regulations as guidance concerning the “transition tax” measures under section 965 as enacted by the U.S. tax law (Pub. L. No. 115-97, date of enactment December 22, 2017) that is at times referred to as the “Tax Cuts and Jobs Act” (TCJA).

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On the OIRA website, the final regulations are identified as:

• RIN: 1545-BO51: Rules relating to section 965 transition tax

These regulations will provide guidance regarding the section 965 transition tax that was enacted as part of the TCJA.


Treasury regulations that are identified as “major” regulations are subject to review by OMB’s OIRA before issuance, pursuant to Executive Order 13771. 

Now that OIRA review has been completed, it is expected that Treasury and the IRS will release the text of the final regulations under section 965. The timing of the release of the regulations, however, is uncertain.

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