Regulations pending OIRA review: Section 954, and coordinating rules under sections 245A and 951A
Regulations pending OIRA review
OMB’s Office of Information and Regulatory Affairs (OIRA) reported that it has received for review from the U.S. Treasury Department final and proposed regulations concerning international tax provisions that were part of the 2017 tax law (Pub. L. No. 115-97)—the law that is often referred to as the “Tax Cuts and Jobs Act” (TCJA).
Treasury regulations that are identified as “major” regulations are subject to review by OMB’s OIRA before being issued, pursuant to Executive Order 13771.
OIRA reported that it received the following regulations for review on July 16, 2020:
- Final regulations—RIN: 1545-BP35: Limitation on deduction for dividends received from certain foreign corporations and amounts eligible for section 954 look-through exception [TCJA]
- Proposed regulations—RIN: 1545-BP57: Rule coordinating application of certain regulations under sections 245A and 951A [TCJA]
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