Law360 Quotes Peter Barnes: IRS Floats Rules for Transition Tax on Foreign Earnings

The U.S. Department of Treasury dashed many corporate taxpayers’ hopes on Wednesday, nixing suggested exceptions or potential areas for wiggle room in regulations to determine how to impose a one-time transition tax on the accumulated earnings of U.S. multinationals’ foreign subsidiaries as part of 2017’s federal tax overhaul.

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“I would not say that Treasury is taking a hard line,” Peter Barnes, of counsel at Caplin & Drysdale, Chtd. and a professor of tax law at Duke University, wrote to Law360 in an email. “Rather, Treasury is following its prior guidance and the legislative history, and not expanding relief for taxpayers in this guidance.”

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Excerpt taken from the article “IRS Floats Rules for Transition Tax on Foreign Earnings” by Alex Parker and Molly Moses for Law360.