Previously Taxed Income Rules to Be Updated Post-GOP Tax Law

The IRS is planning on publishing regulations on previously taxed earnings that take into consideration changes to international tax provisions made by the GOP’s 2025 tax law, an agency official said Friday.

The IRS has been working on a number of guidance projects under the agency’s priority guidance plan, including PTEP rules “taking into account the OB3 considerations,” Daren Gottlieb, attorney at the IRS’s Office of Chief Counsel, said, referring to the tax law.

Gottlieb, who was speaking at a conference in Boston sponsored by the International Fiscal Association, added the agency is working on guidance under Section 897(h), ...