IRS Staffer Details Reasons for Previously Taxed Income Tracking

Proposed regulations require tracking of previously taxed income on both the shareholder and corporate levels because shareholders are the ones affected by that income, and the corporate tracking flows from that, an IRS official said Friday.

US shareholders of foreign corporations are going to be “the primary focus” of tracking previously taxed earnings and profits, or PTEP, Chadwick Rowland, a senior technical reviewer for the IRS Office of Chief Counsel (International), said during an International Tax Institute webinar. Shareholders are the ones who recognize foreign-currency gains or losses, and who ultimately claim credits like deemed paid credits for foreign taxes ...