IRS Proposes Rules for Corporations’ Previously Taxed Income (2)

The IRS issued long-awaited proposed regulations for how companies should treat their previously taxed earnings and profits, or PTEP.

The proposed rules (REG-105479-18, RIN 1545-BO61) for tax code Section 959, released Friday, are meant to prevent double taxation, after the 2017 tax overhaul significantly increased the amount of PTEP.

PTEP is foreign income that a taxpayer brings back to the US after US taxes have already been levied on it.

“This long awaited tranche of guidance is setting forth the fundamental framework and operation of the PTEP rules,” said Joe Calianno, managing director at Andersen. “What is ...