Analysis and observations
The U.S. Treasury Department and IRS on November 29, 2024, released proposed regulations regarding previously taxed earnings and profits (PTEP) of foreign corporations and related basis adjustments.
These proposed regulations were published in the Federal Register almost six years after Treasury issued Notice 2019-01, which announced Treasury’s intention to withdraw PTEP proposed regulations released in 2006 and issue proposed regulations under sections 959 and 961 that would take into account various statutory changes, such as those introduced by the enactment of Pub. L. No. 115-97 (often referred to as the “Tax Cuts and Jobs Act” or TCJA).
Read a December 2024 report prepared by KPMG LLP that provides analysis and observations of the proposed PTEP regulations.