In this Tax Notes Talk podcast, Raymond Wynman, the managing director of GTM’s International Tax practice, discusses the final rules on section 965, specifically the 965(b) basis-shifting election and the specified payment rule. 965b basis-shifting election specified payment rule
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.