Following the publication of Income Tax Regulations (Winter 2019), the IRS issued 13 Notices of Proposed Rulemaking (NPRMs), many of which implement and interpret provisions of the Tax Cuts and Jobs Act. Due to the significance of such guidance for 2018 tax compliance and for other planning purposes, Wolters Kluwer has published this Supplement to the 2019 Edition.
Income Tax Regulations: Tax Cuts and Jobs Act Proposed Regulations Supplement includes the text of proposed regulations issued after the publication of Income Tax Regulations (Winter 2019). The proposed regulations included were issued after November 2, 2018, through January 15, 2019.
Among the topics covered by these proposals are those relating to:
- Reduction of Code Sec. 956 income inclusions by domestic corporations owning stock in controlled foreign corporations
- Treatment of the estate tax exclusion amount when the basic exclusion amount differs for lifetime gifts and at death
- Infrastructure safe harbor for the Code Sec. 163(j) limit
- Foreign tax credits, including the addition of separate foreign tax credit limitation categories for foreign branch income and global intangible low-taxed income (GILTI)
- Base erosion and anti-abuse tax (BEAT) under Code Sec. 59A
- Treatment of a foreign person’s transfer of interest in a partnership engaged in the conduct of a trade or business in the United States under Code Sec. 864
- Treatment of hybrid dividends under Code Secs. 245A and 267A
The Income Tax Regulations: Tax Cuts and Jobs Act Proposed Regulations Supplement will include all final, temporary, and proposed regulations issued after November 2, 2018.