Treasury Seeks Comments on Foreign Affiliate Taxable-Year Change

The Treasury Department and the IRS are interested in comments on a variety of aspects of the way proposed regulations on a taxable-year change for US companies’ foreign subsidiaries will work.

The comments pertain to guidance the agencies issued in November on how companies can allocate their foreign taxes after the giant tax-and-spending law enacted in July eliminated a “one-month deferral rule” that allowed the foreign subsidiaries to elect their tax year.

“If folks have any questions or comments on that, we’re happy to hear from you,” said Laura Shi, an attorney in the IRS Office of Associate Chief Counsel ...