The 2017 tax overhaul reformed international tax rules in the U.S., including requiring companies to bring home offshore profits.
Nearly a year and a half later, companies are still waiting for final guidance from the Treasury Department on many of those international rules. If the government finalizes rules by June 22, 2019—18 months after the passage of the tax bill—they will be retroactively effective to the date of the law’s passage. But if not, there could be a period of time in which the regulations wouldn’t be effective.
“Treasury doesn’t want that gap,” Gregory Jenner, a partner at Stoel Rives ...