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.
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