Finalized Section 965 Transition Regs: Adjustments to E&P and Basis
For a summary of the changes brought forth under the final regs, see our article “Finalized Section 965 transition regs: An overview,” also in this issue. Here we’ll focus on adjustments to earnings and profits (E&P) and basis, as well as the application of Sec. 986(c) dealing with previously taxed E&P. Deferred Foreign Income Corporations … Continued