Proposed regulations were issued in August 2018 on the mandatory one-time transition tax imposed on U.S. shareholders with respect to the untaxed post-1986 foreign earnings of certain foreign corporations. Newly issued guidance impacts two of the provisions in the proposed regulations. U.S. shareholders will be allowed an extended period of time to elect to make certain basic adjustments. Additionally, a more favorable taxpayer rule will be included in the final regulations for determining the aggregate foreign cash position of a U.S. taxpayer who is a member of a consolidated group. Filing relief is also provided to taxpayers who are affected by Hurricane Florence.

These changes could impact you favorably, and we would like to assess your situation to make sure that, if applicable, you can take advantage of these provisions.

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Please call our office so that we can discuss this guidance on the complex and mandatory one-time tax.