March 21, 2019
Sec. 965 Final Regulations: Finally, a Little Flexibility
On January 15, 2019, the IRS released final regulations on the Sec. 965 toll tax (T.D. 9846). In this post, we highlight changes to the 965(b) basis-shifting election and the specified payment rule which add a welcome degree of flexibility to the 965 calculation. If taxpayers wish to take advantage of the revised basis-shifting election, they must act by May 6, 2019. Calendar-year taxpayers who have already filed their 2017 returns should consider whether filing an amended return reflecting the modified specified payment rule or any of the other changes in the final regulations may be beneficial. Read this blog to learn more.