On August 1, 2018, the United States Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) released proposed regulations providing clarification to Section 965, the “transition tax”, which was enacted as part of the Tax Cuts and Jobs Act of 2017[1], as the United States tax system moves to a modified territorial tax …

Continue reading "FGMK TAX ALERT: The Newly Issued Proposed Regulations and Their Impact on the new Section 965 “Transition Tax”"