On November 29, 2024, the Treasury Department (“Treasury”) and the Internal Revenue Service (“IRS”) announced proposed regulations (the “Proposed Regulations”) (REG-105479-18) regarding previously taxed earnings and profits (“PTEP”) of foreign corporations and related basis adjustments. The IRS requests public comments on the proposed rulemaking, which aims to clarify the tax consequences of PTEP under Sections 959 and 961 of the United States Internal Revenue Code of 1986, as amended (the “Code”){{1}}.
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