AICPA Submits Comments on PTEP Basis Adjustments Regulations

AICPA submits comments on PTEP basis adjustments regulations

The American Institute of CPAs (AICPA) has submitted comments to the US Department of the Treasury and the Internal Revenue Service (IRS) on proposed regulations concerning Previously Taxed Earnings and Profits (PTEP) and related basis adjustments. The regulations under Sections 959 and 961 of the Internal Revenue Code are designed to prevent double taxation of US shareholders with income from controlled foreign corporations (CFCs). The proposed…

AICPA Comments on Proposed Regulations Regarding the Previously Taxed Earnings and Profits and Related Basis Adjustments Under Sections 959 and 961

The proposed regulations provide rules addressing various aspects of the PTEP regime, such as increases and decreases to basis of stock, foreign currency gain or loss, and allocation of foreign tax credits.