Trickle Down Guidance: Interim Notices Tackle Key International Reforms

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On April 2, in quick succession, the IRS and Treasury announced notices addressing two provisions added by the Tax Cuts and Jobs Act (TCJA): the repatriation tax under Section 965 and withholding on non-publicly traded partnerships under Section 1446(f ). Given the statutory provisions’ immediate impact – and in the case of Section 965, retroactive effect – official guidance and transitional relief cannot reach taxpayers fast enough.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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